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Sport Pilot Response
Comments sent to the FAA in response to the NPRM


For Comment to the Sport Pilot NPRM GO TO
Comments from EAA can be found at    http://www.sportpilot.org/nprm/docket_comments.html
Comments from AOPA can be found at  http://www.aopa.org/whatsnew/newsitems/2002/020506comments
Comments from USUA can be found at  http://usua.org/SportPilot/CommentNow.htm
Comments from ASC can be found at http://www.aerosports.org/
All comments sent to FAA can be viewed at  DOT Docket Management System (DMS)    In Docket Search enter 11133

NAPPF Comments
NAPPF comment were sent by Sol Lovas, Roy Beisswenger, Ralph McClurg and Jim Sweeney.  The comments can be found on the DMS System outlined above.  The comments from Sol Lovas are posted below.


These comments are from Sol Lovas, NAPPF Regional Director, Northwest

Docket Management System

US Department of Transportation

Room Plaza 401

400 Seventh St., SW

Washington, D.C. 20590-0001

 RE:     Sport Pilot NPRM Comments

            Docket No. FAA-2001-11133

 Submitted by Fax to Docket Office at 202-493-2251

 Faxcopy To:   EAA at 920-426-6560

                        Asc at 616-781-7400

 To the FAA and the US Department of Transportation:

 My name is Sol Lovas.

 I am an ASC-certified Advanced Flight Instructor for Powered Parachutes.  I have been involved in the sport since the spring of 1995.  I became a BFI in the fall of 1995, and achieved AFI status in the fall of 1996.  I was the first female AFI to be certified in the United States.  I am currently a regional director of the NAPPF (North American Powered Parachute Federation), and I serve as its Treasurer, and as the Chair of its Education/Safety Committee. 

 I am a part-time dealer and instructor/examiner for powered parachutes.  I am also a full-time attorney practicing law in Montana, therefore my powered parachute activities are a part-time, but important, second business for me. I have sold and/or trained in Six Chuters, Buckeyes, Destinys, and Powrachutes.  In the last 7 flying seasons, my dealership has sold 31 powered parachutes, and located easily a dozen more used powered parachutes for local pilots.  I have personally solo-trained 38 pilots, and I have successfully trained or checked off 16 BFI candidates.  In addition, I have given many, many introductory flights.

 I am approaching Sport Pilot from the perspective of a part-time powered parachute dealer in the sparsely populated Northern Rocky Mountain/Plains regions.  There simply are no full-time dealers/instructors in this area, because this area does not have the population base to support a full-time dealership.

 Sport Pilot is a good idea in concept for powered parachutes, for three major reasons.  First, it signifies recognition and acceptance of powered parachutes by the general aviation industry.  Powered parachute pilots will now be “real” pilots.  Second, Sport Pilot allows for carrying passengers without the “fiction” of the pilot being an instructor.  Third, Sport Pilot will separate out the professional flight instructors - who will become Sport Pilot Instructors - from those who became a BFI in order to carry their family and friends - who will become Sport Pilots.  All of this is very good, but it will truly happen only if Sport Pilot works as a practical matter for the powered parachute industry.

Unfortunately, the current draft of the Sport Pilot proposal simply will not work for the powered parachute industry, particularly in sparsely-populated areas.  If Sport Pilot is enacted as it now stands, it will not fulfill its intended function of providing a relatively cheap and easy license for powered

parachute pilots, and it will drive the part-time dealer out of business.  It has been hard enough to get pilots of two-seat powered parachutes to comply with the current BFI requirements.  As currently drafted, it will be much more difficult and expensive for pilots to achieve Sport Pilot status, and there will therefore be widespread noncompliance.

I am currently recommending to my customers that they go ahead and achieve BFI status under the current exemptions, even with the duplication period involved, as it appears that it will be significantly  easier and cheaper to become a BFI and transition to Sport Pilot status, than it will be to achieve Sport Pilot status directly.

I also have serious concerns about the certification and ongoing maintenance requirements for a Light Sport Powered Parachute.

In addition, as a part-time dealer/instructor, I have serious concerns about how Sport Pilot will affect my ability to continue in this business.

Finally, I have serious concerns about how the process of transitioning from the current system to the Sport Pilot system will occur.



A.  “15 hours flight training in a powered parachute from an authorized instructor and at least 5 hours of solo flight training” is required to qualify for Sport Pilot.  How many of the 15 hours are required to be full dual instruction, that is, student and instructor both in the PPC in the air?  This language reads as if all 15 hours must be full dual instruction.

The current industry standard (established by ASC and EAA) is 3 hours of full dual instruction, and many instructors (including myself) feel that this is more than is needed.  Generally, a half hour of dual instruction is all that is needed prior to soloing (and even that isn’t really necessary - many powered parachute pilots (myself included) soloed without ever having been up in a powered parachute!).  Once the pilot has their basic solo hours in (25 for a BFI), it only takes an hour or so of flight (which should include 2 or 3 takeoffs and landings) to become accustomed to the changes in flight caused by the extra weight of a passenger.  Additional time with an instructor in the back seat is superfluous, and represents only an added expense for the student, and a complete waste of time for the instructor. 

Further, any dual instruction requirement should be geared to number of takeoffs and landings, rather than hours of flight time, since that is where the extra weight makes the most difference (this point is discussed more thoroughly in I.E below).  I submit that a requirement of 5 dual takeoffs and landing with an instructor in the back seat would be more than sufficient.  And most of this should be done toward the end of training, not the beginning.

An alternative would be to allow flights with significant weight in the back seat to substitute for flights with an instructor in the back seat.  This is a very common PPC training technique, particularly with part-time instructors.

It must be remembered that powered parachute flight is very weather dependent.  It is hard enough to find a flight window for a single BFI flight check.  To tie the student and instructor up with needless dual time in the air will make achieving a Sport Pilot license an unattainable goal.  In this part of the country, there simply are no full-time PPC instructors who can devote the time required, and the pilots do not have the time to wait around the instructor’s flight field hoping for enough weather windows for dual instruction.  The result will be either falsified logs, or complete non-compliance.

B.  Flight training:

            i.  Canopy collapses and meta-stable stalls.  No way am I going to tell a student to go up and deliberately collapse his or her canopy, or attempt to initiate a meta-stable stall!  That’s dangerous and potentially life-threatening.  These are extremely rare occurrences in the PPC world. Students need to know how to respond if it happens, but they should not try them for practice.

            ii.  Cross-wind takeoffs and landings.  In a PPC, the correct training for these is not to do them!  If you are significantly cross-wind, don’t take off.  Explain how to come down cross-wind, yes! But practicing it is dangerous (cross-wind is the single most significant cause of PPC rollovers!).

            iii.  Power-out maneuvers.  Straight glides and gliding turns are power-off maneuvers. Most PPCs are pull starts, with the pull handle overhead and well behind the pilot.  Once the engine is off, it is sometimes impossible to manually restart it in the air, leading necessarily to a power-off landing.  Since PPCs land themselves, even without power, power-off landings are not generally taught or practiced, especially since most PPC flying in our area is done from short fields.  Idle landings, yes (they are good training for power-off landings, but can be aborted if necessary). Power-off, no.

C.  Cross-country flight training and experience.  I agree completely with the ARAC position that cross-country privileges should be a separate training and endorsement privilege, and not required for Sport Pilot.  Cross-country in a powered parachute, because of weather constraints, is almost always a group activity, with significant ground support following along, in case the weather goes bad and you cannot return to the takeoff field.  Therefore, it is not a common activity, and many powered parachute pilots simply do not do cross-country flights.  In reality, PPC  “cross-county” usually consists of trailering the PPC to a new field and flying in the vicinity of the new field, rather than flying to a new field. 

I am a prime example of this.  I have approximately 300 hours of PPC flight, but I have logged only 3 flights which qualify as cross-country flights under the NPRM rules, for a total of 4:50 flight time.  And I had 30 hours of flight in before I even tried a significant cross-country.  I have another 4 flights logged of 10-miles plus out and back, for another 6:25,  but they don’t qualify as “cross-country” flights according to the NPRM definitions (because there was no leg over 15 nm, and on three of the flights, there was no touchdown at the farthest point).

D.  10 takeoff and landings “at an airport”.  This is (a) undefined, (b) probably unrealistic, and (c) inconsistent with other provisions.   (a) & (b)  Most PPC flying and training is done from open fields or unregulated (and probably unregistered) private turf/dirt airstrips in rural areas.  Are theses “airports” for this purpose?  PPCs are often not welcome at general aviation airports.  The first time I flew from a general aviation airport with a paved strip, I already had 25 hours of flight time, and I have flown in and/or out of a general aviation airport with a paved strip only 14 times in my approximately 300 hours of PPC flight (and those were all uncontrolled rural airstrips, except for one, which was an uncontrolled suburban airstrip). (c) As Sport Pilot is currently drafted, flight into controlled B, C, or D airspace will require separate training and endorsement beyond basic Sport Pilot.  What’s left - Class E and G uncontrolled airports? Are there many of those?

If the “airport” requirement is retained, some clarification is needed.

E.  10 takeoff and landings.   Actually, more takeoffs and landing should be required, but not necessarily at “airports” (see above).  Once in the air, PPCs just about fly themselves.  The only significant inflight skill required is to learn how to offset turns with throttle, so you can compensate for the altitude loss from turning.  Other than that, the flight skills required to safely fly a PPC involve chute and throttle management during takeoffs and landings.  Actually, takeoff - laying out the chute, and getting the chute inflated and centered - is the most difficult and dangerous part of flying a PPC.  When I solo a student, I relax once they are off the ground.  The hardest part is over.  Flight is a no-brainer, and landing is simple.  20 hours of flight time is an appropriate place to grant passenger-carrying privileges (although 25 would be consistent with the current industry standard). However, that flight time should include at 25 takeoffs and landings to a full stop, with the chute on the ground, requiring re-layout prior to takeoff. Currently, 10 flight hours with 25 takeoffs and landings  is the current ASC flight requirement for a PPC pilot.

F. 3 hours flight training within 60 days of practical test.  It is completely unrealistic to  require the student, the instructor, the examiner, and the weather, to all get together within such a tight time frame.  3 hours of flight time within 60 days I could understand, to ensure currency for the safety of the examiner during the flight check.  But given weather constraints and the likely general unavailability of examiners in sparsely populated areas, even that will often be difficult to achieve.  A better approach would be to apply the regular currency standard: 3 takeoffs and landings within 90 days  prior to the test. (See I.E above - takeoffs and landings are far more important in a PPC than time in the air.)

G.  Make and model limitation: This is a problem area throughout the Sport Pilot provisions for the PPC industry.  The only significant differences between the different makes and models of PPCs on the market are: (a) different throttle placement and function (side v. center, forward = more gas v. back = more gas) (b) front wheel steering (there are several different versions of this), (c) rectangular v. elliptical chutes, and (d) hard-point chute attachment to the frame v. tilt-bar attachment.  The elliptical chutes do fly differently than the rectangular chutes, and do require additional and different training.  I have not flown a tilt-bar attached chute, and I would definitely want someone to explain the differences to me before trying one. But everything else is basically the same!  Throttle changes are simply a matter of remembering which way is more gas.  Front wheel steering is obvious, and taxing up and down the field once or twice is enough for that issue. Requiring the time and expense of additional training (for both the student and the instructor) to switch from a Six Chuter to a Powrachute to a Buckeye, all with rectangular hard-point attached chutes, is ridiculous.

H.  Biannual Flight Review.  This is overkill for PPCs, and will be a practical problem.  Right now, in our area, we have problems getting all the BFIs to a ground school class once every two years.  Given the weather constraints on PPCs, getting an actual flight check in once every two years will be very difficult from a scheduling standpoint.  If the flight check could consist of the instructor on the ground - viewing possibly several students laying out, taking off, flying in the pattern and landing, under radio supervision - it could maybe be done. Again, chute layout, takeoffs and landings are far more important than time in the air.  But even that is more than is currently required. A full hour of dual-in-the-air-flight for each pilot biannually will simply not be doable in practice, particularly for a part-time instructor, which is all there will be in many of the less-populated  areas of the country.


A.  Inspection rating: I understand this rating is supposed to be the equivalent of an experimental aircraft builders license to maintain and inspect his or her own plane, but without the 51% requirement which prevents a buyer of a used experimental plane from getting a similar license.  This will therefore allow the buyer of a used experimental PPC the opportunity to get a license for their own PPC, which is a very good thing!  However, many of the PPCs registered as experimental will be built by the owner from a more-than-51% pieces-and-parts kit.  I submit that pilots who build their own PPC from a kit should be exempted from the 16-hour school requirement. The 16-hour school option would then be available to those who bought a pre-assembled PPC (used or new).   Without such an exemption, getting everyone trained within the transitional time limits will be difficult.

Furthermore, 16 hours is excessive.  Owners need to be able to inspect and make minor repairs to the airframe, synchronize dual carbs, check the engine for visible and audible problems, and check the chute and lines for any problems.  This can easily be covered in one day.

And if they sell their Buckeye to buy a Powrachute, they have to take the school all over again because this is a different “make and model”!?!  Completely unnecessary.

B.  Inspection of kit-built planes.  The NPRM indicates that in order to register a kit-built PPC as an experimental PPC, it will have to be inspected by  FAA personnel prior to flight.  Will there be enough inspectors to do this on a timely basis?  And where will they be located? And what will an inspection cost?  Currently, before I permit a student to solo in their own PPC, I personally inspect, and generally fly, the PPC myself.  If it is a newly-constructed unit, I have to fly it first to be sure the chute is attached and trimmed properly. Even if the unit has been previously flown, I generally fly it first to ensure that the chute is trimmed appropriately for a beginner.  This is typical of the industry.  Will the FAA inspectors fly the units to check chute trim?  I doubt it, yet that is the single most important part of the first flight of a PPC.  I submit that inspection of the airframe by an instructor or a light-sport maintenance rating should be sufficient inspection, and the PPC’s first flight should be done by a Sport Pilot or Sport Pilot Instructor, not a student/owner.  It takes experience to rig and trim a chute correctly.

And what is this business about Phase I flight testing?  If it is built from a kit based on a “special” light-sport plane (an “eligible kit”), why require a period of flight testing?  If the prototype has been established as safe, as long as the kit is assembled correctly, it will fly.

C.  Registration numbers.  Most PPCs don’t have any place to put 3" letters.  The current industry standard is 1 ˝ " letters, which do fit on the tubular parts of the airframe.  And “horizontal” won’t work.  There aren’t many horizontal tubes on a PPC.  Currently, many registration numbers are displayed vertically on the pylons or wheel shock struts.  Some PPCs have horizontal gas tanks that would work as a display area, but many PPCs have vertical gas tanks, which would not fit 3" horizontal marks.


To be a fully-functioning PPC dealer under Sport Pilot as currently drafted, the dealer will need to be (or have on staff) a Sport Pilot in order to give people free introductory flights, a Sport Pilot Instructor to be able to charge for introductory flights and to train new pilots, and a Maintenance rating to be able to do any significant maintenance to a customer’s PPC (including final inspection prior to flight). The dealer/instructor will also have to fly a “special”-registered PPC to be able to use it for paid flight instruction (including introductory flights).

A.  Building a kit for a customer.  What rating/license will be required to permit a dealer to build a PPC from the manufacturer’s kit for a customer, if the PPC  will be registered as an “experimental” PPC?  Nothing?  Or a Maintenance rating?  It isn’t clear.  The answer probably should be: a Maintenance rating.  If you need a Maintenance rating to work on it for hire once it is built, you probably should have a Maintenance rating to build it for hire.

B.  Sales Demos.  According to the NPRM, a Sport Pilot will be permitted to demo a registered PPC in flight to a prospective buyer only if he or she is not an “aircraft salesperson.” An “aircraft salesperson” has to be a FAA-licensed private pilot in order to demo the PPC to a buyer.   Most PPC dealers, including myself, are not private pilots, and do not intend to become private pilots.  Will a Sport Pilot Instructor who is also a dealer/salesperson be permitted take a prospective buyer up in a PPC?  If not as a “demo” flight, can they do so by calling it a “training” flight?  I certainly hope so (one way or the other), otherwise there will be very few PPC dealers left once Sport Pilot is fully implemented.

C.  Limiting “Special” registration to “factory-built” PPCs.  The net result of the Sport Pilot NPRM as written will be to require all dealer/instructors to own “special” registered PPCs, which are required to “factory-built”.  Fully-assembled PPCs cannot be flown to their new owner, nor can the new owner fly them home.  They have to be shipped to their new owner by truck, or trailered.  Doing this over any distance is prohibitively more expensive than shipping a kit.  I submit that a properly-trained (factory-certified) dealer/instructor in the field is fully as capable of assembling a PPC as the factory (in cases of experienced dealers vs. new factory personnel, probably better and faster).  Therefore, allowing certified  dealers/instructors with maintenance ratings to assemble special-registered PPCs will not decrease safety, and the certification process would still be under factory control.  This should be allowed.

D.  Three-year rule for existing trainers. If certified dealers will be allowed to build  new “special” PPCs from kits, there is little reason not  to allow existing dealer-built trainers to transition to “special” registration (although inspection would still be required in this instance).  This would simultaneously (1) eliminate the requirement that all instructors buy new "special" PPCs within the first three years of Sport Pilot; (2) eliminate the need for the special 3-year period for allowing existing dealer-built trainers to be used for paid instruction, and (3) simplify and render more affordable the process of transitioning from dealer/instructor status under the exemptions, to dealer/instructor status under Sport Pilot.  The manufacturers can specify which of their previous models meet the consensus standard (or how they can be modified to do so).  Making all the instructors buy new factory-built machines within the first three years of Sport Pilot, when they have been safely training for years in PPCs they have built,  is a needless expense, and it may drive many existing dealers out of the business, rather than face the costs of compliance.

Alternatively, existing trainers should, after inspection, be available to be used for training for a longer period of time, say 10 years or 2000 hours.

E.  Inspecting new “special”-registered PPCs.  Once the consensus standard is adopted, and manufacturers comply therewith, requiring an FAA inspection of each and every “special”-registered PPC (built by the factory or by factory-certified dealers) seems unnecessary.  The authority to inspect at will is obviously necessary, and occasional random checks should be done to ensure compliance, but with the way the PPC industry is growing, inspecting each and every new “special”-registered PPC will be a major undertaking, and will be unnecessary to ensure quality manufacturing by the responsible industry leaders.  If inspection is required, it should be done at the factory, prior to delivery to the buyer, for all factory-built units, and by Maintenance ratings in the field for non-factory-built units.

F.  80 hour requirement for a Maintenance rating.  This is excessive.  80 hours is a two-week course.  That is not enough to teach complete engine maintenance or chute repair, but is way too much for airframe inspection, repair, and maintenance.  In the PPC industry,  the dealer in the field will take serious engine problems to an engine repair shop, and will send chutes needing anything other than line replacement or minor patching back to the factory for repair.  That really leaves only the airframe to be maintained for the customer, and it doesn’t take 80 hours of class to learn how to inspect and maintain a PPC airframe, and how to recognize problems with the engine or chute that should be sent to others.  20 is probably enough, and 40 would, I am sure, be more than adequate, given those restrictions.  And each course obviously needs to cover and certify for more than one make and model!

G.  Flight requirements for a Sport Pilot Instructor rating.  The flight time requirements for a Sport Pilot Instructor for PPCs is 100 hours (50 in a PPC), including 15 hours of cross-country flight (5 in a PPC), and 15 hours in a light-sport PPC.  These are unnecessarily high requirements.

(A) Many, if not most, PPC dealers/instructors have never flown anything but a PPC.  Why require them to have 100 hours in a PPC, when pilots with other experience only have to have 50 hours in a PPC?  Flying anything else doesn’t help you fly a PPC.  In fact, it hurts.  The worst solos in PPCs are done by pilots with lots of time in other aircraft, because everything they know about how to control an aircraft is absolutely wrong for powered parachutes.  Raw beginners do much better, because they have nothing to unlearn. 

(B)  It is hard to get 15 hours of cross-country flight in a PPC.  I have a total of almost 300 hours in PPC flight, and of that amount, only 4:50 qualifies as cross-county flight time as defined in the NPRM. (See I.C. above) And only 2:30 of that (one flight) occurred within my first 50 hours of flying. 5 hours of cross-country flight in your first 50 hours of PPC flying would be a lot!  I don’t even have 5 in 300 hours of PPC flying.

(C)  Why require 15 hours in a “light-sport” PPC.  Under Sport Pilot, what other kind of PPC would they be flying (except maybe 103 legal PPCs)?  Better to require 15 hours dual flight (with a passenger, not necessarily an instructor) in a PPC - that’s the really important issue (and again, a set number of takeoffs and landings would be better and more useful than set hours of flight).

I submit that the “other” flight aspect should be entirely disregarded, and the requirements set at 50 hours of PPC flight, including 3 cross-country flights, and 15 (or maybe even 25) dual takeoffs and landings.

H.  Make and Model restrictions.  As I read the NPRM, before I can train or endorse a student in a particular make and model of PPC, I have to be trained and endorsed for that make and model, and have 5 hours of flight experience in that make and model! As stated in section I.G above:

“The only significant differences between the different makes and models of PPCs on the market are: (a) different throttle placement and function (side v. center, forward = more gas v. back = more gas) (b) front wheel steering (there are several different versions of this), (c) rectangular v. elliptical chutes, and (d) hard-point chute attachment to the frame v. tilt-bar attachment.  The elliptical chutes do fly differently than the rectangular chutes, and do require additional and different training.  I have not flown a tilt-bar attached chute, and I would definitely want someone to explain the differences to me before trying one. But everything else is basically the same!  Throttle changes are simply a matter of remembering which way is more gas.  Front wheel steering is obvious, and taxing up and down the field once or twice is enough for that issue.”

 It is ridiculous to assert that an instructor who trained in a Six Chuter single-seater or two-seater is not capable of flight testing or training a student to fly a Powrachute.  It is ridiculous to assert that an instructor who trained in a Buckeye two-seater is not capable of training someone to fly a Buckeye single-seater.  Or that someone trained in a Buckeye 582 two-seater can’t train someone to fly a Buckeye 503 two-seater.  Yet each of these is a different “make and model”, for which Sport Pilot would require additional training, endorsement and 5 hours flight time.  Six separate trainings, endorsements, and 30 hours of flight time are required to teach in what is basically six versions of the same  machine????  And then what happens if someone shows up with a Destiny or a Harmenings High Flyer?  I can’t fly it for them to trim it out, or teach them in it, unless I have an endorsement and 5 hours flight experience in that “make and model”?  This has to be modified to something based on flight characteristics (such as rectangular v. elliptical chutes), rather than make and model, in order to be workable and sensible in practice. (Either that, or get rid of the five hours, and  recognize that the required “training” may be as little as a phone conversation with the factory.)


 A.  Initial Flight Review for BFIs transitioning to Sport Pilot.  For the reasons set forth in I.H above, the requirement of an initial  dual-in-the-air flight check for BFIs transitioning to Sport Pilot is impractical.  Furthermore, it is unnecessary overkill as applied to PPCs.  Each BFI has already been signed off by an AFI as competent to fly two people.  Requiring the same thing again is redundant and overly expensive in terms of both time and expense for student and examiner.  And since the transitional  flight check would have to be done by an EXAMINER (as opposed to an INSTRUCTOR), the practical issues of getting it done within the time window provided for transitioning are daunting!  Who will be the initial examiner(s) for my area, and how far away will they be and how willing will they be to travel?  And at what cost?  I understand the need for a knowledge test, since Sport Pilots will be subject to many rules and regulations that currently do not apply to ultralights.  But another flight check - by an EXAMINER - is completely unnecessary, and practically undoable.  At the very least, if an initial transitional flight check will be required, let it be done by an INSTRUCTOR (rather than an EXAMINER, but not the Instructor who initially trained the pilot), under the more relaxed rules set forth above in I.H for biannual flight reviews (radio supervised solo flight). This at least has a possibility of being actually doable within the time frames required.

 B. Inspections of existing ultralight trainers.  The NPRM requires an FAA inspection of all existing PPCs to be registered as “experimental” PPCs.  There are thousands of these out there. Does the FAA have the personnel to do this?  How accessible will that personnel be and what will be the cost?  Are they trained for this for PPCs?  Better to use PPC Inspection or Maintenance ratings for the inspection process.  Additional safety could be achieved by requiring the inspector to be someone other than the person who built the PPC.

 C.  Dual licensing.  During the transitional phase, pilots, instructors, and examiners will be required to maintain their ratings under the exemptions until the qualification process is completed (for both pilot and machine) under Sport Pilot.  Given the delays I anticipate, this could get very expensive, particularly if there is a timing hangup on one side (pilot or machine) but not the other.  I submit that during the transitional phase, either a BFI or a Sport Pilot (including instructors and examiners) should be able to fly either an ultralight trainer PPC or a registered light sport PPC. That would minimize duplication during the transition period and make it much easier to transition. Whenever the pilot got the sport pilot rating, he or she could drop the BFI, but could still fly the PPC as an ultralight trainer until it was certified as a light-sport PPC.  Or if the pilot got the PPC registered before achieving Sport Pilot, the light sport PPC could be flown by the pilot as a BFI.

 D.  Examiners.  Who will be the initial PPC Examiners?  The NPRM indicated they will be drawn from the pool of existing AFIs, but will additional FAA “Examiner” training be required?  And how much will it cost?  And what will it cost (both in terms of time, training, and expense) to maintain an Examiner rating?  Will existing general aviation flight examiners be willing or able to do PPC flight checks?  If willing, what additional training would be required, and would many existing examiners be willing to undertake the expense of the training, give the small size of the PPC market (as compared to the rest of general aviation)? (And given the general lack of respect accorded  PPCs by the general aviation community?)


 As written, Sport Pilot will work fairly well for private pilots who have lost their medicals or for other reasons wish to transition to lighter aircraft; for those who wish to fly aircraft at the higher end of the weight and speed limits of Light Sport Aircraft; for those who wish or need to fly in highly-populated areas; and for those who wish to use their Light Sport Aircraft commercially (such as rentals).  As such, it is an important step forward for the aviation industry in general.  But it is serious overkill for the recreational PPC industry.

 I submit that an alternative approach that  would work better for the PPC industry (and probably for most of the trikes and fixed-wing ultralights) would be an "Ultralight SFAR" attached to Part 103 (like the proposed Sport Pilot SFAR will be attached to Part 61) that would create a new FAA Ultralight Pilot license.  Such an SFAR could:

a.                                                       Make permanent the existing rules for becoming an ultralight flight instructor (BFI) or examiner (AFI) with the authority to train for hire in two-place ultralights that fit within the current definition of ultralight trainers (496 pounds, 10 gallons, 75/35 max/stall speed), but under direct FAA supervision (with existing instructors and examiners truly grandfathered in as FAA-recognized ultralight instructors and examiners);

b.                                                      Allow licensed ultralight pilots to carry passengers (not for hire) in two-place ultralights that fit within the above limits (with existing BFIs who do not intend to professionally instruct to be grandfathered in as ultralight pilots); and

c.                                                       Allow licensed  ultralight pilots to fly “fat” single-seat ultralights (up to certain specified limits, such as 360 lbs, 10 gallons, 75/35 max/stall speed);

while retaining the rest of Part 103's restrictions (no congested areas, no night flying, ATC only with permission, etc.). Retaining the other Part 103 restrictions would eliminate the need to inspect and certify the planes themselves, but registration would be required (as it is now).  Flying a Part 103-legal single-seat would still be possible without training or regulation, but to fly anything heavier or two-place would require registration, training by a BFI, and checkoff by an AFI.  This would get all two-place and fat ultralighters the appropriate training to make them safer fliers, but it would be simple enough that it has a chance of actually being accomplished by all of the two-place and fat ultralight pilots currently out there flying illegally.

Or at the very least, simply consolidate and retain the current training exemptions and their training requirements as an "Ultralight Instructor SFAR" attached to Part 103, along with the Sport Pilot SFAR attached to Part 61.

I am very afraid that if the only choices are “illegal” or “Sport Pilot”, too many will choose “illegal”.  The current system is effectively getting the two-place PPC and ultralight pilots into BFI compliance, and it has been proven that the current training requirements for flying the two-place units do work in practice, do promote safety, and are accomplishable by the recreational ultralight pilot.  More is simply not needed.  Therefore, why not simply accept, adopt and  make permanent the existing training requirements established by the ultralight industry, which are already working quite well ?

A new Ultralight SFAR as proposed above is really all that the recreational end of the PPC industry needs or has asked for.  Furthermore, it would achieve the stated goals of Sport Pilot - to promote safety by requiring appropriate training, but keep it simple given the simplicity of the craft involved - much better than the current draft of Sport Pilot will.  PPC manufacturers would then have the option of selling PPCs which would qualify as either ultralights under the Ultralight SFAR, or Light Sport Aircraft under the Sport Pilot SFAR, and new pilots could choose their approach - 103-legal, Ultralight SFAR license, or Sport Pilot SFAR license.


If Sport Pilot is adopted as currently set forth in the NPRM as it applies to powered parachutes, I foresee a number of results.

First and foremost, there will be massive non-compliance by owners of two-seat powered parachutes.  Sport Pilot will be much more difficult to comply with than the existing BFI structure.  Given the safety and simplicity of powered parachutes, requiring more will not increase safety, it will only increase non-compliance.

Second, there will be no place in Sport Pilot for the part-time dealer/instructor.  The training requirements alone will be undoable for a part-time instructor.  The combination of training and maintenance requirements to provide a full-service dealership will simply not be possible on a part-time basis.  Yet there is not yet enough of a market in PPCs in most areas to financially justify attempting to do this on a full-time basis!

The combined result will be a reversion to the worst of the past - insufficient training and support, and untrained owners flying illegally.

Please do not do this to what is currently the fastest-growing segment of the private aircraft industry, and the one with the most potential to bring new pilots into aviation.  Please do not destroy by over-regulation the best thing that has happened to private aviation in a long time!

Sincerely yours,

Sol Lovas, AFI

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