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07/19/2004: Sport Pilot Press Conference

On Tuesday, July 20, 2004, USUA.ORG will be attending a 10:30AM press conference at Federal Aviation Administration Headquarters 800 Independence Avenue, Washington DC, to hear FAA Administrator Marion Blakey introduce the historic new Sport Pilot/Light Sport Aircraft rule. The stage has been set for this announcement by recent approval of the rule by the White House Office of Management and Budget (OMB), after a long period of evaluation. Representatives from many aviation news services will be attending this press conference, with USUA EVP Dale Hooper representing the USUA web news service. . It has been reported that FAA is going all out for this press conference, including having actual Light Sport Aircraft type aircraft displayed on Independence Avenue.

USUA will be reviewing the final rule when it is published in the Federal Register, and will publish a detailed report, designed to aid members in their preparation for Sport Pilot and Light Sport Aircraft registration.

07/16/2004: Sport Pilot Is On It's Way!

USUA is pleased to announce that after months of evaluation, the Sport Pilot/Light Sport Aircraft Rule has been signed by the White House Office Of Management And Budget, and preparations have already begun by FAA for it's release sometime next week.

As was reported earlier by USUA Headquarters, the final rule will look different than the NPRM, which was published in the Federal Register Feb. 5, 2002. Meetings are scheduled between FAA, USUA, EAA and ASC to discuss the final rule, and the implementation procedures involved. No details concerning any changes are available at this time.

In the coming weeks, USUA members with questions concerning the specifics of the final rule can look to the USUA website for updated information , and USUA Regional Representatives will soon be supplied with detailed materials to help members and clubs with localized support. USUA will provide access to materials and support for all members who choose to participate in Sport Pilot.

The release of Sport Pilot is only the beginning. There will be a period of time before the rule is effective, which will allow prospective Sport Pilots, the opportunity to position themselves for participation. It will also allow for the creation and registration of Sport Pilot instructors and examiners. Instructors desiring involvement on these levels will soon be provided the opportunity to do so.

In preparation for this rule, USUA urges all members who have not yet done so, to register as ultralight pilots. If you are in the process of becoming a BFI, finalize that registration soon. These ultralight registrations will allow you to take advantage of special transitional provisions FAA has put in place for registered ultralight pilots and instructors wishing to participate in Sport Pilot.

After so many months of preparation, USUA applauds FAA in their continued dedication to this project, which will allow USUA members yet another option to "Fly For Fun".

06/30/2004: Sport Pilot DPE Applications

At 5PM, Tuesday June 29,2004, USUA EVP Dale Hooper participated in a teleconference with FAA EAA and ASC, discussing the Sport Pilot Designated Pilot Examiner (DPE) registration program. Reports of inaccurate information that have recentlybeen circulated throughout the industry, prompted FAA to call this meeting in order to clarify the registration process.

First, it must be clear that the process has not yet begun. Sport Pilot hasnot been signed, and no action can be taken regarding any of the particularsof the final rule, until it has been published. At that time, DPE applicants will be able to download an application from the FAA AFS-610 website. This FAA application will be the only document that will be accepted for CFI/DPE registration.

DPE registration is open to anyone, regardless of organizational affiliation. In fact, no affiliation is required for application. If theapplicant is a member of one of the major ultralight organizations (USUA,EAA, or ASC), they may obtain an endorsement from that organization. Thisendorsement will add to the value of the application.

All USUA Basic and Advanced Flight Instructors are encouraged to consider becoming a Sport Pilot DPE, or CFI. "It is critical that we have as many Light Sport DPEs and CFIs that are knowledgeable and competent with ultralight aircraft as possible participate in these programs" commented USUA Director Jim Sweeney.

USUA will provide accurate information regarding Sport Pilot and the regulatory process as it becomes available.

On 7/6/2004, Dale discussed this issue on Ultraflight Radio. Listen to it here.

06/01/2004: Sport Pilot Returned to OMB

In a long awaited move, FAA has returned the Sport Pilot/Light Sport Aircraft initiative to the Office Of Management And Budget (OMB) for final approval. As was reported by USUA in March, FAA withdrew the rule from OMB, allowing FAA to address questions posed regarding the economic cost/benefits raised during the OMB review. The recent action of returning the rule to OMB, allows the initiative to make it's way back into the system.

Because the rule was returned from OMB at FAA request, the rule is not subject to the previous 90-day timeframe for review. OMB has the option to review it as quickly as it sees fit. When the rule is finally approved by OMB, it will travel back to FAA, this time for publication in the Federal Register. After publication, there will then be a period of time before the rule becomes effective.

All reports from FAA indicate that the Sport Pilot/Light Sport Aircraft rule is being handled as top priority by high level government officials, and that release is forthcoming.

03/25/2004: Sport Pilot Update

On March 24, 2004, it was officially announced that FAA had requested that the proposed Sport Pilot rule be returned from the Office Of Management & Budget, to FAA. This action was taken by the Administrator to address issues that seem to have been of concern to OMB. The rule was not sent back by OMB, as was erroneously announced days earlier at an industry Safety Seminar, but was withdrawn by FAA request.

By withdrawing the rule by FAA's own request at this time, it could save the rule from being rejected by OMB, and keep it from having to pass through theentire regulatory process once again -- possibly avoiding a rewrite orworse. USUA applauds FAA for taking this action. This decision will eventually help expedite the Sport Pilot/Light Sport Aircraft regulations, allowing those anxiously awaiting the final rule the opportunity to participate in this long awaited program. Manufacturers, dealers and pilotsof aircraft that will be affected by these rules have endured difficult times throughout the process, and any effort to bring this matter to fruition is welcome.

USUA will stay on top of the ongoing situation, and provide more information, as it becomes available. As stated before, USUA will onlyreport verifiable information from FAA sources.

United States Ultralight Association, Inc.
Dale Hooper
Executive Vice President

03/23/2004: Sport Pilot Rumors Abound; And They Are Just That - RUMORS

As Sport Pilot/Light Sport Aircraft weaves it's way through the regulatory process, much anticipation and concern is felt by all who will be affectedby the new rules. Under these circumstances, rumors and misinformation canbe interpreted as truth.

Recently, at the Virginia State Ultralight Safety Seminar, at which I was privileged to attend, it was reported by FAA that Sport Pilot was sent backto FAA for a re-write, and that the rule was effectively on hold. Because this information was given by the local Richmond FSDO Safety Program Manager, much interest was given to his statement. After hearing this, Iimmediately contacted Sport Pilot Program Manager Sue Gardner forverification and clarification. Ms. Gardner replied directly to me viaphone, just minutes ago, that this information was NOT CORRECT. She statedthat the rule was NOT SENT BACK TO FAA FOR A RE-WRITE, AND THAT IS WAS INDEED STILL AT THE OFFICE OF MANAGEMENT AND BUDGET PROGRESSING AS EXPECTED.She would give no time frame for the rule to be released, however it is safeto expect release later this year.

For those of us hungry for new information concerning this very importan tregulation, it is sometimes easy to fall victim to any rumor that mayprovide insight into what to expect. USUA cautions everyone to wait until information is provided from the highest levels of FAA before jumping to any conclusions. USUA is in direct communication with persons in those offices,and will post only confirmed updates.

12/24/2003: USUA received a phone call at 10AM EST, December 24, 2003 from Sue Gardner of FAA informing us that late yesterday afternoon, the Secretary of the Department of Transportation has signed off on the proposed Sport Pilot/Light Sport Aircraft Rule. It now goes to the Office of Management and Budget, the final step in the rulemaking process. OMB is expected to use their allotted 90 days to evaluate the rule and act accordingly. If all goes well, and there is little to expect otherwise, we may see SP/LSA sometime after April 2004.

"This is great news for our community," says USUA EVP Dale Hooper, "USUA members who have not yet registered as ultralight pilots, are encouraged todo so immediately so that the special provisions allowed to persons holdingthis registration may be taken advantage of."

USUA will continue to monitor the development of these proceedings and encourages all members to visit the USUA website for any and all news andannouncements.

- Dale Hooper, USUA

12/31/2003: Prepare For Sport Pilot Now!

Very soon, the Sport Pilot/Light Sport Aircraft rule will be released. This will happen after it receives support from the three government entities(FAA, DOT/OST and OMB) that are required to sign off on the rule. FAA andDOT/OST have already given approval. According to all indications from FAA,there will be some intere sting developments immediately following the implementation of the Sport Pilot/Light Sport Aircraft Rule. After the ruleis released, there will be a period of time (typically from 30-90 days)before the rule will actually be implemented. This will be the effectivedate. At some point during this time some fundamental changes will happen tothe existing ultralight programs, most notably, the use of the trainingexemption. It is unclear at this time whether the changes will take place onthe date of release or the effective date. For the purpose of allowingmaximum participation in existing programs, USUA advises anyone planning onparticipating in industry registration programs to do so before the releasedate.

It's widely understood that the existing training exemptions will stay in place for a period of time, to allow for the transition of instructors andpilots. However, there are strong indications from FAA that after therelease of the Sport Pilot rule, there will be no new instructors created tooperate under the current exemptions. This means that from that day forward,existing instructors will be able to continue to instruct, but no new BFIswill be allowed. This is a significant concept. Many people, who have beenprocrastinating about finalizing their BFI training to be an instructor,might find themselves left out in the cold regarding the availability of theexisting training exemptions. USUA suggests that if you are pursuing the BFIrating, you should complete the process now.

FAA offers special provisions to registered ultralight pilots. These provisions include the waiving of flight time/experience requirements forultralight pilots registered with the existing programs and transitioning toSport Pilot status. There also seems to be some basis for concern regardingthe availability of these special provisions for those who will register asultralight pilots after the release/effective date of the new rule. If youare late to register as an ultralight pilot, the special provisions may notbe available to you. Also, reg istered ultralight pilots will have 24 months in which to make the transition and take advantage of these specialprovisions. Those who wait will find it more difficult and more expensive tomake the transition. USUA suggests that you complete your ultralight pilotregistration now.

The same is true with your airplane. You will have 24 months in which, if you so choose, to N-number your airplane as experimental Light SportAircraft, and 12 months to have it inspected. This does not necessarilyallow 36 months for you to make this all happen, however the particularswill be spelled out in the final rule. What is clear is that if you do notadhere to the prescribed time frame for LSA registration, you may not beable to register your airplane as experimental Light Sport Aircraft.

The bottom line, if you choose to participate in Sport Pilot/Light Sport Aircraft. Follow through with your ultralight airmen registrationsimmediately. Do not wait.

Dale Hooper
Executive Vice President
United States Ultralight Association, Inc.

12/24/2003: Sport Pilot Signed Off By DOT

USUA received a phone call at 10AM EST, December 24, 2003 from Sue Gardner of FAA informing us that late yesterday afternoon, the Secretary of the Department of Transportation has signed off on the proposed Sport Pilot/Light Sport Aircraft Rule. It now goes to the Office of Management and Budget, the final step in the rulemaking process. OMB is expected to use their allotted 90 days to evaluate the rule and act accordingly. If all goes well, and there is little to expect otherwise, we may see SP/LSA sometime after April 2004.

"This is great news for our community," says USUA EVP Dale Hooper, "USUA members who have not yet registered as ultralight pilots, are encouraged to do so immediately so that the special provisions allowed to persons holdingthis registration may be taken advantage of."

USUA will continue to monitor the development of these proceedings and encourages all members to visit the USUA website for any and all news and announcements.

- Dale Hooper, USUA

8/4/2003: Sport Pilot/Light Sport Aircraft - Now What?

FAA Administrator Marion Blakey in the crowds shortly after making an announcement about the new rules - Click photo for full sized image

By now, most folks know that FAA Administrator Marion Blakey has signed the Sport Pilot/Light Sport Aircraft rules and passed them on to the Department of Transportation (DOT). After DOT completes their review, the rules will go to the White House Office of Management and Budget (OMB).

The question on most of our minds is how long will it take?

How long will it be before the rules become final? How long after they become final will the rules actually become effective?

Guess what? We don't know! Nobody does! Speculations continue!

It appears our aviation industry and community needs to settle in for what could be a another period of months before the rules become final. The Secretary of Transportation, (OST) and the Office of Management and Budget are allowed to scrutinize the proposed rules, for as long as 90 days each. Do the math! If both agencies use the maximum amount of time for their reviews, it will be at least 6 months before the final rules emerge.

After the rules become final, an implementation phase will follow. At this time, the expected duration of the that phase of the rule making process is anyone's guess.

During the meeting in which the Administrator made the announcement about the rules, Phil Lockwood (Lockwood Aviation) asked a very important question. Phil asked why, since the administrator has approved the draft, that details of the proposed rule could not be revealed. Citing the hardships that uncertainties about the rules have made on the ultralight industry thus far and the serious negative impacts that are expected, Phil asked the Administrator to provide specifics. The specific details would help companies create strategies that could make them comp etitive by the time the rules become effective.

Administrator Blakey, said that she must remain silent on the details contained in the proposed rules. "We don't like it either," she said, citing the fact that rule making laws and regulations prevent her from disclosing any details prior to the rules being deemed final.

An optimistic Sue Gardner, FAA Sport Pilot Team Manager, said "while it is true that DOT and OMB are entitled to 90 days each, we know we sent them a very finished document, one that thoroughly covers the issues. This is a very important set of rules we are working on, one of the most complex the agency has ever done, it takes time to get it right and that's best for all concerned."

According to Rich Pendergist, USUA Executive Vice President, "It is not very surprising to learn of yet another extended wait for the final rules, but we are committed to making your transition to Sport Pilot and the Light Sport Aircraft rules, as easy as possible when and if pilots decide to do so".

Many USUA members will choose to continue their operations under Part 103 and USUA is committed to protecting the tried and true Part 103. "Part 103 is alive and well and USUA will continue to provide training and aircraft registration even after the effective date of the SP/LSA rule," said Pendergist. "While change may be inevitable, it doesn't have to be difficult. USUA will continue to serve its members and provide a smooth path for those who choose to make the transition into the new operating environment. In the meantime, I encouraged everyone to go fly and also to introduce someone new to the sport. We should certainly continue to use the current operating environment to have fun while we wait for the legislators to do their thing," he concluded.

07/31/2003: Sport Pilot Update - From Airventure

At about 12:00PM, July 31 2003, FAA Administrator Marion Blakey announced that she had signed off on the Sport Pilot/Light Sport Aircraft (SP/LSA) rule and passed it on to the Department of Transportation (D OT), moving it to the second step in the rulemaking process. After passing DOT, the rule goes on to the Office of Management & Budget (OMB) for final assessment.

She went on to say that it could take six months to a year before the final rule is released. However, by her own admission, she has a tendency to "under promise and over deliver," meaning that the rule may be finalized sooner.

Administrator Blakely also publicly thanked USUA and the other ultralight organizations for their tremendous efforts and support thus far.

When the Administrator was asked specific questions relating to details of the SP/LSA rules, these questions went unanswered. Ms. Blakey explained that she was bound by legal restrictions and, therefore, could not respond. As more news relating to the SP/LSA announcement develops, it will be posted at the USUA web site.

Marion Clifton Blakey was sworn in September 13, 2002 as the 15th Administrator of the Federal Aviation Administration. As Administrator, Blakey is responsible for regulating and advancing the safety of the nation's airways as well as operating the world's largest air traffic control system. Prior to being named FAA Administrator, Blakey served as Chairman of the National Transportation Safety Board.

07/24/2003: SP/LSA Rumors

Speculation continues about whether the FAA Administrator will make public the new Sport Pilot/Light Sport Aircraft, SP/LSA, rules in Oshkosh, WI when she addresses a forum at EAA's Airventure the end of this month.

USUA has learned that, contrary to rampant rumors the SP/LSA rules have not been signed by the FAA Administrator and have not been forwarded to the Office of Management and Budget (OMB) at this time (1535Z 072403).

According to a spokesperson at FAA Headquarters Public Affairs Office, moments ago, the rules are "being worked very hard" by FAA officials and must still be reviewed by OMB and DOT before becoming final.

- Rich Pendergist

06/24/2003: Sport Pilot NPRM and Exemption 4274 Near Sunset - New FAA Rules Coming

It may be the next-to-last time it happens, but USUA mailed the latest extension of Exemption 4274 to its BFI’s on June 19.

When the SportPilot/Light Sport Aircraft rules become effective, perhaps in late 2003 or early 2004, the training exemption to Part 103 will be on a count down to extinction. Rumors abound, but if all goes according to the Notice of Proposed Rule Making (NPRM), the exemption will disappear 36 months after the effective date of the new rules. Therefore, there will only be a one-year extension (or less) of the exemption when the present extension expires in July 2005. (full story).

06/03/2003: ASTM Light-Sport Aircraft Committees Update

By Tom Peghiny

The American Society for Testing and Materials (ASTM) Light-Sport Aircraft (F-37) committee met in Kansas City, Missouri, May 7-9, 2003 for a series of general committee meetings and various subcommittees as well. I had never been to Kansas City before and was impressed by the architecture of the buildings and some impressive monuments. (full story).

05/23/2003: FAA’S New Light Sport Aircraft Program Office Established

The FAA has authorized the establishment of a Light Sport Program Office to ensure national standardization and implementation of the new sport pilot/light-sport aircraft rule. The new office will be in Oklahoma City under the Flight Standards Regulatory Support Division. This office will be responsible for the implementation and continued update of policy and advisory materials required for the Sport Pilot/Light-Sport Aircraft Rule.

Other key functions and responsibilities for this office are:

04/30/2003: USUA Chats With FAA Officials at Sun-N-Fun (Full story)

History:

Registered Ultralight Pilot to Sport Pilot

SUMMARY

This addresses the steps proposed by FAA in NPRM 11133 for an ultralight pilot, who is registered in an FAA recognized ultralight registration program before 24 months after the effective date of the rule, to obtain a sport pilot certificate from FAA.

You would have to meet minimum age, language, and medical requirements.

You also would have to pass the appropriate knowledge and practical tests for the certificate.

You would not have meet the aeronautical knowledge, flight proficiency, and aeronautical experience requirements in the FAA proposal if you have log evidence of more than minimum time.

The proposal would require you to obtain a notarized copy of your ultralight pilot records from the FAA-recognized ultralight organization. Those records would document that you are a registered ultralight pilot with that FAA-recognized ultralight organization; and would list each category and class of ultralight vehicle that the organization recognizes that you are qualified to operate.

You would still have to pass the knowledge test and practical test (oral and flight) for a sport pilot certificate. An FAA Designated Pilot Examiner (DPE) would administer the practical examination.

The proposal would require you to present records, along with the results from the knowledge test, to a designated pilot examiner or FAA inspector when applying for your sport pilot certificate. The designated pilot examiner or FAA inspector would review these records and document the appropriate endorsements for each category and class of ultralight vehicle that you are qualified to o perate in your applicant's logbook, after you successfully complete the practical test.

Your sport pilot certificate would authorize you (assuming you obtained the two logbook endorsements: ATC airspace and faster light sport aircraft) to fly with another person in aircraft that could sustain more than 130 mph (115 kts), fly over cities and into airports that require ATC communications. This is much more authority than the present-day ultralight pilot, or even ultralight instructor, is granted.

For a glimpse of how the NPRM's name, FAR placement, aircraft definitions, operating privileges and grandfathering were developed during the ARAC process, and in some cases discarded by FAA later, see a piece of ARAC History.

ANALYSIS

Minimum age, language and medical requirements: You would have to meet minimum age, language, and medical requirements (driver's license). The minimums follow, to demonstrate the relative number of requirements:

In lieu of the provisions of 14 CFR 61.23(a)(3)(iii), which require a student pilot to hold an airman medical certificate, you must hold and possess while exercising the privileges of a student pilot certificate to operate a light-sport aircraft or a sport pilot certificate, when operating other than a glider or balloon:

(a) A current and valid U.S. driver's license; or

(b) A current and valid airman medical certificate issued under 14 CFR part 67.

USUA's FAA-recognized ultralight training program allows students to begin training at age 14 and pilots to be registered at age 16. FAA has not shown accident data indicating a decrease in safety at these ages versus the proposed age 16 for students and 17 for pilots. Higher age minimums limit when new people can begin learning to fly and thus inhibits growth of the industry. This is contrary to FAA's stated purpose of the Sport Pilot proposal.

Registered ultralight pilots would not be required to receive and log ground training.

Ultralight pilots (now a sport pilot student) would not have to receive and log ground training from an authorized instructor or complete a home-study course on aeronautical knowledge areas before taking the sport pilot written test. This is good for those who had successfully completed an FAA-recognized ultralight training program compared to those who had not.

This is also the basis for the term "grandfathering" but does not adequately explain that written, oral and flight testing requires the applicant to exhibit knowledge and skill at the sport pilot level. These additional steps are unnecessary for those who wish to fly slowly within the limited scope of Part 103 operating rules and have already been trained and tested through an FAA-recognized ultralight training program.

Items covered in the written test follow, to demonstrate the comprehensive nature of the list. While FAA does not require existing registered pilots to receive instruction in these areas, they must be prepared in every area of knowledge and proficiency in preparation for the written, oral and flight tests. To read the areas, click

Take sport pilot written test
The registered ultralight pilot must present to FAA his sport pilot application form (filled out), ultralight registration card (ultralight association), and the required test fee (usually around $70.00) to an authorized FAA testing center. You must pass the written test.

Meet minimum flight experience requirements
FAA proposes to accept flight experience for registered ultralight pilots who have logged all of the required time. This is good for those who have successfully completed an FAA-recognized ultralight training program compared to those who had not. The term "grandfathering" has been widely used in a way that minimizes the effort the ultralight pilot must expend just to continue flying.

Minimum flight experience requirements vary according to the category of aircraft.

The flight experience requirements follow, to demonstrate the relative number of requirements:

Notarized copy of training record
Then, with your written test score sheet and a notarized copy of your ultralight association instructor registration card, you could seek (and pay for) an FAA designated pilot examiner or an FAA aviation safety inspector (who is qualified in that category, class, and make and model of light-sport aircraft) to conduct the oral and flight (practical) test. You must pass the test.

USUA does not understand why FAA proposes a notarized copy of the association record. Notarization would add $10.00 to the cost of providing USUA registration verification. If similar costs were applied to the other associations and FAA estimates "10,000 ultralight pilots" will transition to sport pilot, there would be $100,000 in unnecessary expense. In addition, the ultralight associations do not routinely verify that an individual instructor's reported flight time is accurate or record cross-country time by instructors.

The registration card received by each registrant should be satisfactory evidence for FAA purpose here because that is exactly what FAA asked the associations to produce for "satisfactory evidence of compliance." Each "FAA recognized" association already produces a written response. It is usually incorporated into the membership card and includes the pilot/instructor/owner's name, address, and ultralight category.

Obtaining a notarized copy of an association record adds an unnecessary expense and could slow down the process, depending on how quickly an association could respond to requests, for an ultralighter wishing use his or her association records to obtain a sport pilot certificate.

Practical Examination
You would be required to pass the oral and flight examination (practical) on the areas of operation listed below. Also included are all knowledge areas relative to the written test, and certainly any items missed on the written test.

  1. Technical subject areas
  2. Pre-flight preparation
  3. Pre-flight lesson on a maneuver to be performed in flight
  4. Pre-flight procedures
  5. Airport, seaplane base, and gliderport operations, as applicable
  6. Takeoffs (or launches), landings, and go-arounds
  7. Fundamentals of flight
  8. Performance maneuvers and for gliders performance speeds
  9. Ground reference maneuvers (except for gliders and lighter-than-air)
  10. Soaring techniques
  11. Slow flight and stalls (stalls not applicable to lighter-than-air and gyroplanes)
  12. Spins (applicable to airplanes, gliders, and weight-shift-control aircraft)
  13. Emergency operations
  14. Post-flight procedures

This additional step is unnecessary for those who wish to fly slowly within the limited scope of Part 103 operating rules and have already been trained and tested through an FAA-recognized ultralight training program.

RECOMMENDATIONS

USUA supports the proposed sport pilot option for those ultralight pilots who want to fly two-seat aircraft for fun and recreation in as much as 130 mph aircraft.

However, USUA does not see safety data indicating need to so dramatically increase the requirements for those who have shown a preference for slower, more open cockpit flying over rural areas in aircraft similar to those currently operated under Part 103. FAA apparently agrees by stating in NPRM 11133 that the success of existing ultralight pilot registration programs [single and two-place ultralight] "exemplifies the ability of the aviation industry to take responsibility for the safety of its flight operations." So, let's just use similar programs for pilots of single place craft which modestly exceed the limitations of ultralight vehicle definition. (See H. O. Malone)

Embody the training exemption programs in the FAA rules.
USUA believes safety is best served by continuing to support a method for those ultralight in structors who like slow, rural operation. FAA should write the exemptions into a permanent Special FAR that relates to FAR part 103 (Ultralight Regulation) just as sport pilot is a Special FAR related to parts 61 & 91.

USUA sees no reason to penalize existing ultralight pilots who want to simply continue ahead with what they have done for years, and, according to FAA, are doing a good job.

Ground Training: USUA believes that the authority to operate over cities has made the numerous ground training topics relevant for sport pilot applicants. However, for those who operate "fat" ultralights, especially single-seaters, and who are willing to remain limited to operating in rural settings as ultralights are required to do, the proposed ground training requirements are excessive and not warranted on the basis of safety. The ground training items listed in FAR part 103 (Ultralight Regulation) have proven adequate for those who operate "ultralights" in rural areas.

Therefore USUA objects to requiring such extensive training for those flying the more limited "fat" ultralights and recommends continuing to use the existing ultralight programs for those pilots. Such operating authority could be included in the Special FAR related to FAR 103 (Ultralight Regulation) as recommended above.

Notarized training record
USUA recommends that FAA not require notarization of an instructor's association records. Instead, the registration card received by each registrant should be satisfactory evidence for FAA purpose here because that is exactly what FAA asked the associations to produce for "satisfactory evidence of compliance."

FAA Pilot Examiners and FAA Aviation Safety Inspectors USUA experience indicates that few existing FAA ASIs or DPEs will cross over into "ultralight" type aircraft for flight tests. In particular, very few existing DPE/ASI will choose to do weight-shift (trikes) and powe red parachutes.

This is another reason to continue the existing ultralight training exemptions (written into the FARs). FAA should allow ultralight instructors (potentially future DPEs) to continue to operate without being forced to expand into 130 mph aircraft. These ultralight instructors, and future incoming ultralight instructors, are the pool of potential sport pilot instructors and DPEs.

USUA again recommends that the existing training programs be continued by incorporating them into an S-FAR associated with FAR part 103 (Ultralight Vehicles).

USUA, you are right on track! I support your views and want to contribute to the cause as a member. Sign me up now.

Ultralight Instructor to Sport Pilot Instructor

Step 1: Ultralight Instructor to Sport Pilot

SUMMARY
This addresses the first step for existing ultralight instructors to become sport pilot instructors. The first step is for the ultralight instructor to apply and obtain a sport pilot certificate.

FAA proposes a method for existing ultralight instructors (two-seat training by exemption) to become sport pilot instructors. The method requires the ultralight instructor to first become a sport pilot by working with an existing sport pilot instructor to prepare for, and then pass an FAA written test. Then an FAA Designated Pilot Examiner (DPE) administers the oral and flight-test (now called practical test) to the ultralight instructor who wants to become a sport pilot.

If the ultralight instructor has already logged more flight instructional time than FAA would require of new sport pilots, FAA would require only 3 flight training hours with a sport pilot instructor in preparation for the flight test.

FAA proposes to terminate the ultralight training exemptions 3 years after a final rule, t hereby eliminating all ultralight instructor's privileges who did not obtain a sport pilot instructor certificate.

The sport pilot would be authorized (assuming he/she obtained the two logbook endorsements: ATC airspace and faster light sport aircraft) to fly with another person in aircraft that could sustain more than 130 mph (115 kts), fly over cities and into airports that require ATC communications. This is much more authority than the present-day ultralight instructor is granted, and here he/she has only reached the sport pilot level.

ANALYSIS
Ultralight instructors have 3 years to comply.
If you are a registered ultralight instructor with an FAA-recognized ultralight organization (no later than 36 months after the effective date of the final rule) and you want to apply for a flight instructor certificate with a sport pilot rating, you must hold either a current and valid sport pilot certificate or at least a current and valid private pilot certificate issued under 14 CFR part 61.

How to start the transition
If you do not have an FAA private pilot certificate, you must first become a sport pilot student.

Begin as student pilot

Existing ultralight instructors must comply or stop instructing.
FAA proposes to terminate the existing ultralight training exemptions within 3 years after issuing a ruling. Any ultralight instructor who has not completed the transition to s port pilot instructor by then would not be allowed to conduct flight instruction.

Minimum age, language and medical requirements
You would have to meet minimum age, language, and medical requirements (driver license).

The minimums follow, to demonstrate the relative number of requirements.

Existing Ultralight instructors would not be required to receive and log ground training.

Take sport pilot written test
The ultralight instructor must present to FAA his sport pilot application form (filled out), ultralight registration card (ultralight association), and the required test fee (usually around $70.00) to an authorized FAA testing center. You must pass the written test.

Meet minimum flight experience requirements
FAA proposes to accept that flight experience for ultralight instructors who have logged all of the required time. Hence the term "grandfathering" which has been widely used in a way that minimizes the effort the ultralight instructor must expend just to continue flying, and yet more to continue teaching.

Minimum flight experience requirements vary according to the category of aircraft.

The flight experience requirements follow, to demonstrate the relative number of requirements. To read the requirements, click Show me the minimum flight experience requirements.

Show me the minimum flight experience requirements.

Notarized copy of training record
Then, with your written test score sheet and a notarized copy of your ultralight association instructor registration card, you could seek (and pay for) an FAA designated pilot examiner or an FAA aviation safety inspector (who is qualified in that category, class, and make and model of light-sport aircraft) to conduct the oral and flight (practical) test. You must pass the test.

FAA believes new FAA examiners will primarily come from existing AFIs.

Logbook endorsement for make/model from FAA inspector or designee.
After successfully passing the practical test for a sport pilot certificate, you would be issued a pilot certificate. The FAA designated pilot examiner or FAA aviation safety inspector would also make the appropriate logbook endorsements establishing that you are proficient in this category, class and make and model of light-sport aircraft; as a pilot, not as an instructor.

CommentNow, the individual who was already authorized to teach ultralight flying, some as long as 19 years under FAA exemption, is finally a sport pilot. He may fly over cities and with a one or two-place aircraft which can su stain 87 kts (100 mph). With only two logbook endorsements, fly an aircraft that can sustain 115 kts (132mph), and fly into ATC controlled airspace.

But he may not instruct in it yet.

Now he may begin to apply for sport pilot instructor.

Click here. for USUA view of the FAA title for this portion of the proposal.

RECOMMENDATIONS
USUA supports the proposed sport pilot option for those ultralight instructors who want to move up to sport pilot instructor so as to possibly teach in 130 mph aircraft.

However, USUA does not see safety data indicating any need to stop those existing (and future) instructors who wish to continue teaching in two-seat ultralights and who have shown a preference for slower, more open cockpit flying over rural areas. FAA apparently agrees by stating in NPRM 11133 that the success of these [single and two-place ultralight] flight training programs "exemplifies the ability of the aviation industry to take responsibility for the safety of its flight operations."

Embody the training exemption programs in the FAA rules.
USUA believes safety is best served by continuing to support a method for those ultralight instructors who like slow, rural operation. FAA should write the exemptions into a permanent Special FAR which related to FAR part 103 (Ultralight Regulation) just as sport pilot is a Special FAR related to parts 61 & 91.

Those BFIs who wish to teach flight of 130 mph (115kts) aircraft over cities may take advantage of the new system proposed here by FAA. Existing BFIs who only want to fly for fun and give rides may become sport pilots. But USUA sees no reason to penalize existing ultralight instructors who want to simply continue ahead with what they have done for years, and, according to FAA, are doing a good job.

Ground Training
USUA believes that the authority to operate over cities has made the numerous ground training topics relevant. However, for those who operate "fat" ultralights, especially single-seaters, and who are willing to remain limited to operating in rural settings as ultralights are required to do, the proposed ground training requirements are excessive and not warranted on the basis of safety. The ground training items listed in FAR part 103 (Ultralight Regulation) have proven adequate for those who operate "ultralights" in rural areas.

Therefore USUA objects to requiring such extensive training for those flying the more limited "fat" ultralights and recommends continuing to use the existing ultralight programs for those pilots. Such operating authority could be included in the Special FAR related to FAR 103 (Ultralight Regulation) as recommended above.

Notarized training record

USUA recommends that FAA not require notarization of an instructor's association records. Notaries normally charge $10.00 per signature. With the FAA estimate that "10,000 ultralight pilots" will transition to sport pilot, there would be $100,000 in unnecessary expense. Instead, the registration card received by each registrant should be satisfactory evidence for FAA purpose here because that is exactly what FAA asked the associations to produce for "satisfactory evidence of compliance."

FAA Pilot Examiners and FAA Aviation Safety Inspectors
USUA experience indicates that few existing FAA ASIs or DPEs will cross over into "ultralight" type aircraft for flight tests. In particular, very few existing DPE/ASI will choose to do weight-shift (trikes) and powered parachutes.

This is another reason to continue the existing ultralight training exemptions (written into the FARs). FAA should allow ultralight instructors (potentially future DPEs) to continue to operate without being forced to expand into 130 mph aircraft. These ultralight instructors, and future incoming ultralight instructors, are the pool of potential sport pilot instructors and DPEs.

There is, of course, no present demand for sport pilot examiners because the sport pilot rule is only being proposed. After issuance of a final rule, assuming it similar to the one proposed now, FAA expects a rapidly increasing number of sport pilot applicants who would seek examinations. With an increasing demand for sport pilot examinations, there would be incentive for ultralight instructors to move into the sport pilot (then sport pilot instructor, then DPE) arena. This is a normal supply-and-demand situation.

However, if the sport pilot rule appeals to just a few applicants, as is the case with recreational pilot, there will be little need for sport pilot instructors and DPEs. By continuing to provide for instructors in the more limited ultralight vehicles, FAA would be assuring a stable, perhaps growing, pool of potential sport pilot instructors and DPEs for a future time when the number of sport pilot applicants created sufficient demand for more examiners.

USUA again recommends that the existing training programs be continued by incorporating them into an S-FAR associated with FAR part 103 (Ultralight Vehicles).

To read more about the history of two-seat ultralights, click here.

Ultralight Instructor to Sport Pilot Instructor

Step 2: AFI/BFI who has sport pilot and is now applying for sport pilot instructor (CFI)

SUMMARY
An ultralight instructor, who has already obtained a sport pilot certificate from FAA, may then apply for sport pilot instructor (CFI). He/she would then have to satisfactorily meet the following FAA requirements (according to FAA NPRM 11133).

PASS WRITTEN TEST-AERONAUTICAL KNOWLEDGE
You would be required to pass the FAA knowledge (written) test on the required aeronautical knowledge areas. The knowledge areas are also subject to discussion/questioning during the oral portion of the practical examination.

WRITTEN TEST-FUNDAMANTALS OF INSTRUCTION
An existing AFI/BFI would not need to meet the aeronautical knowledge requirement specified in § 89.113 of SFAR 89 if he/she had passed the Fundamentals of Instruction knowledge test given by the FAA or an FAA-recognized ultralight organization. However, the FAA pilot examiner would be empowered to question each applicant about his/her knowledge of fundamentals of instruction including the following specific items.

PASS PRACTICAL (ORAL & FLIGHT TESTS)
You would be required to pass the FAA practical test in a light-sport aircraft that is representative of the category and class of aircraft for the privilege you seek. During the test you must be prepared to demonstrate your ability to teach all areas in the pilot test standards including stall awareness, spin entry, spins, and spin recovery procedures in an airplane, glider, or weight-shift-control aircraft, as appropriate.

The proposal would require you to present these records, as well as the results from your knowledge test, to a designated pilot examiner or FAA inspector when you apply for a flight instructor certificate with a sport pilot rating.

ENDORSEMENT FOR CATEGORY AND CLASS
After you pass all those examinations, the FAA designated examiner or FAA inspector would review your records and endorse your logbook for each category and class, make and model of light sport aircraft in which you are authorized to fly and provide flight training.

At least 5 hours of flight experience by the instructor would be required in each make/model of light sport aircraft before the instructor could instruct with it.

36 MONTH TRANSITION PHASE
This proposal would establish a transition phase to ensure that ultralight flight instructors have ample time to obtain both their sport pilot and flight instructor certificates with a sport pilot rating. Also, this would allow the FAA-recognized ultralight organizations to continue to instruct under the existing exemptions.

EXEMPTIONS TERMINATED
At the end of the 36 months, the existing training exemptions would expire and would not be renewed.

ALL ULTRALIGHT TRAINERS ILLEGAL
FAA proposes that all two-place training vehicles would be required to become certificated light-sport aircraft and there would no longer be a need for exempted two-seat ultralight trainers.

FAA ENVISIONS SPORT PILOT INSTRUCTORS TEACHING SINGLE-PLACE PART 103The FAA recognizes that persons who wish to operate ultralight vehicles under part 103 would still need to receive training. FAA proposes that a sport pilot instructor could train an ultralight pilot to fly a single-place ultralight under part 103.

ANALYSIS

WRITTEN TEST
This is too much of an increase in requirements and it is unnecessary for those who want fat-singles and two-place ultralights limited to rural areas. Each knowledge area is tested by written examination, but is also subject to discussion/questioning during the oral portion of the practical examination. These questions include the following subject areas:

Ultralighters may find the requirements too burdensome and thus give up flying. The additional burden may also limit the number of new pilots coming into the sport when they discover what is required for the type of limited flying they wish to enjoy.

FAA has no safety data to support this huge increase in knowledge requirements. FAA has never reported safety problems during 20 years of industry administered FAA-recognized ultralight training programs.

WRITTEN TEST-FUNDAMANTALS OF INSTRUCTION
An existing AFI/BFI would not need to take the Fundamentals of Instruction knowledge test if he/she had passed the Fundamentals of Instruction knowledge test given by the FAA or an FAA-recognized ultralight organization. However, the FAA pilot examiner is empowered to question each applicant about his/her knowledge of fundamentals of instruction including the following specific items:

PRACTICAL EXAMINATION
You would be required to pass the oral and flight examination (practical) on the areas of operation listed in proposed § 89.115 of SFAR 89. This includes all knowledge areas relative to the written test, and certainly any items missed on the written test (listed above).

ENDORSEMENT FOR CATEGORY AND CLASS
After you pass the practical test, the FAA designated examiner or FAA inspector would review your records and endorse your logbook for each category and class, and make and model of light-sport aircraft in which you are qualified and authorized to provide flight training. Those make/models are the only light sport aircraft in which you may instruct without further examinations.

For example, if you take the test in a Quicksilver Sport 2 with a ROTAX 582 engine, that is what your log endorsement would reflect. If the engine were replaced with a ROTAX 503, the instructor would be required to receive a logbook endorsement from an authorized instructor who conducted training on the requirements for that (now different) model.

The instructor's logbook endorsement would certify that you (already a sport pilot instructor and ultralight instructor) are proficient to provide flight training in that additional make and model. B ut you may not teach in it until you have at least 5 hours of pilot-in-command time in that specific make and model of light-sport aircraft. Remember, we theoretically changed only the engine size from the one in which the instructor was authorized to fly and teach.

This requirement, as illustrated in the above example, is too burdensome for the type of operation typically conducted under Part 103.

36 MONTHS TRANSITION PERIOD
During this 36-month transition phase, an ultralight flight instructor could continue to instruct in a two-place vehicle under his or her existing exemption (organization registration). This same flight instructor could also hold a flight instructor certificate with a sport pilot rating and be authorized to instruct a sport pilot, a student pilot operating light-sport aircraft, or a flight instructor with a sport pilot rating.

The training aircraft/vehicle would determine the operating rules: an ultralight trainer remains subject to exemption limitations, a light sport aircraft would be subject to its individual operating limitations and part 91 requirements (general aviation operating rules).

EXEMPTIONS TERMINATED
FAA proposes that at the end of the 36 months, the existing training exemptions would expire and would not be renewed. This would eliminate any option to be an ultralight instructor in the traditional sense.

No longer could ultralighters receive training under the rules in which they intended to fly. Initial response from ultralight instructors indicates many may stop providing instruction when the exemptions are terminated. If so, a lack of instructors could lead some to revert back to the old unsafe practice of "self-teaching" which would decrease ultralight safety.

ULTRALIGHT TRAINERS ILLEGAL
Disappearing along with ultralight instructors (exemptions) would be the two-place training vehicles (Part 103 ultralight). Every trainer would be required to meet the definition of a light-sport aircraft and would be required to be certificated as light-sport aircraft. All flight training in a light-sport aircraft would be required to be conducted by a certificated flight instructor. Three years after FAA issues the new rule existing ultralight trainers that had become experimental light sport aircraft would no longer be allowed for flight instruction.

Any leftover ultralight trainers that had not been certificated would be illegal to fly in the United States. The two choices are to certificate the trainer after receiving the manufacturer's "retroactive statement of conformity" for your individual trainer (which is unlikely), or to pass the FAA certification inspection for experimental.

This places a substantial economic burden on present two-place training vehicle owners. To continue offering ultralight flight instruction would require the purchase of a new Light Sport Aircraft. The only ultralight trainer that has also been certificated to allow flight instruction under General Aviation rules is the Quicksilver GT 500. The difference in cost ($16,970 ultralight trainer versus $32,695 for the certificated version) is approximately $16,000; roughly double. Then there could be the additional cost of obtaining FAA pilot and instructor certificates if the pilot does not already have them.

FAA believes new FAA examiners will primarily come from existing AFIs.

The ultralight AFI will have to begin his/her aviation-teaching career all over again beginning at the sport pilot student level. After attaining sport pilot, they shall meet the requirements and pass tests to become a sport pilot instructor. Then they ask to be chosen by FAA and they pay to go to FAA school in Oklahoma City. FAA currently charges $250 for the school that lasts a week. Total average cost including travel and accommodations would be $1,000. This is asking a huge amount of those who are already giving written and oral and flight tests in ultralights.

FAA also notes that FAA Aviation Safety Inspectors (ASI) (these are FAA management employees) may give practica l tests. USUA is aware that there are very few, if any, FAA ASIs who have significant experience in ultralights or who have an inclination to do so.

The result could be a shortage of examiners. Without enough examiners, the required practical tests would be harder to obtain and fewer prospective pilots would be able to complete flight training. The number of new pilots would then be significantly less than FAA estimates and could put into question the cost/benefit of the rule.

Logbook endorsement for make/model from FAA inspector or designee. After successfully passing the practical test for a sport pilot certificate, you would be issued a pilot certificate. The FAA designated pilot examiner or FAA aviation safety inspector would also make the appropriate logbook endorsements establishing that you are proficient in this category, class and make and model of light-sport aircraft as a pilot, not as an instructor.

Now, the individual who was already flying ultralights (albeit a fat one), some as long as 20 years under FAA part 103, is finally a sport pilot. He may fly over cities and with a one or two-place aircraft that can sustain 87 kts (100 mph). With only two logbook endorsements, he may fly an aircraft that can sustain 115 kts (132mph), and fly into ATC controlled airspace.

This is good for those wishing to exercise the full privileges of the certificate. This process is unnecessarily burdensome for those who have already been trained and tested through an FAA-recognized ultralight training program and wish to fly slowly within the limited scope of Part 103 operating rules.

RECOMMENDATIONS

WRITTEN TEST
There is too much of an increase in knowledge for those who want fat-singles and two-place ultralights as now defined and not over cities. The better solution is to also have the option of a special FAR attached to 103 for recreational use of single and two-seaters which exceed Part 103 but meet the training exemption if two-seaters, and meet the H. O. Malone limits if single seaters.

This new, part 103 SFAR, would require a written test associated with operations in part 103, and be very similar to the written tests passed by ultralight instructors today.

The tests would be from FAA and the resulting pilot/instructor certificates would have an FAA logo. FAA would establish standards (by adopting those in current use), and would have full enforcement authority.

The Fundamentals of Instruction test requirement needs no change from that proposed by FAA. It should also be absorbed into the USUA proposed part 103 SFAR along with the other ultralight instructor requirements of the existing industry program.

PRACTICAL EXAMINATION
Same comment as for the written test above. Oral and flight tests for those who request only those privileges allowed by FAR part 103 should be given by ultralight instructors (those who have AFI/BFI) who should truly be grandfathered with no further showing into a new SFAR attached to 103. Allowable aircraft definitions identical to today's ultralight trainers and the fat single-place machines as described in the H. O. Malone petitions.

ENDORSEMENT FOR CATEGORY AND CLASS
USUA recommends only a category and class endorsement requirement, not make/model specific. This would mean a pilot could get one endorsement to fly all trikes that fly off land. Another endorsement would be needed to fly an airplane (changing category) or fly off water (changing class). A pilot would then not need an endorsement to change from a Quicksilver Sprint to Quicksilver Sport.

Also, 5 hours experience in make/model is not necessary on the basis of safety based on past experience with 19 years of two-place ultralight trainer exemption experience. USUA recommends that FAA simply drop make/model endorsement requirements because category and class endorsements adequately satisfy the safety issues associated with changing from one aircraft to another.

36 MONTH TRANSITION PERIOD
USUA recommends that FAA place the two-place training exemptions in a new SFAR. This would allow the existing ultralight instructors to continue teaching. Allow continued operation by ultralight instructors without forcing them to learn to fly and teach in 130 mph aircraft. A new SFAR associated with FAR part 103 could adopt the existing pilot and instructor training programs and codify them to enable FAA oversight and enforcement. An option for program administration by advocate associations should be considered, but is not a requirement of this recommendation. Such organizational delegation would be limited to the application process. Program standards, testing and enforcement would be the responsibility of FAA.

By retaining the existing definition of ultralight two-place trainers in the USUA proposed SFAR, there is no need to push ultralight instructors into parts 61 & 91 or to force them to become pilots and instructors competent to fly 130 mph aircraft. Those instructors who do want the increased privileges proposed by FAA for sport pilot instructors, would have that option in the system proposed in NPRM 11133.

USUA recommends that FAA place a new option for recreational use of two-place ultralights (defined as training planes now are defined) in a new SFAR.
USUA agrees, generally, with the pilot, instructor and aircraft options proposed in NPRM 11133. However, FAA's NPRM 11133 disregards the fundamental simplicities embodied in Part 103 and has gone far beyond the original USUA requests related to ultralight aviation. USUA has great concern that the NPRM will not resolve the original issues that USUA has presented again and again. What USUA continues to seek is reflected in the operational activities we are now involved with, as found in FAR Part 103, FAA exemptions for operation of two-seaters and associated flight activities.

USUA has repeated many times in national publications and in petitions to FAA, that in over 19 years of two-place ultralight instruction authorized by FAA exemptions, one thing is very clear is: Those who learn to fly ultralights with an ultralight instructor in two-place ultralights, learn to fly two place ultralights.

Those who advance to the instructor level have carried "passengers" in the broad sense, with a good safety record and FAA sanction over all those years. Now is the time to allow those individuals who are willing to attain at least 20 hours of experience under an instructor's guidance, and who pass FAA tests (copied from existing ultralight instructor tests) for knowledge (associated with ultralight regulation part 103), and a practical test exactly like the existing ultralight instructor practical, without the teaching portions, to fly these very limited craft (defined exactly like ultralight trainers today) for fun and recreation with one passenger.

The Puzzle's Missing Pieces A number of outstanding implementation issues have yet to be addressed by FAA. These could significantly affect what is required to comply with the proposed rules. Click here to learn more about The Puzzle's Missing Pieces.

To support efforts like these, join USUA.

FAA FLIGHT INSTRUCTOR TO SPORT PILOT INSTRUCTOR

Summary
If you already hold a current and valid FAA flight instructor certificate (CFI) issued under 14 CFR part 61, you could provide flight training toward a sport pilot certificate without further showing of proficiency.

The FAA CFI's would be limited to providing instruction in the same aircraft category and class listed on his/her existing pilot certificate and flight ins tructor certificate. The instructor must have at least an FAA 3rd class medical certificate or a valid drivers license.

FAA instructors would have to receive training on any specific make and model of light-sport aircraft in which they had not acted as pilot-in-command. This means they would need a logbook endorsement from the authorized instructor [another sport pilot instructor] who conducted their training certifying proficiency in that make and model of light-sport aircraft. For example to step from a ROTAX 503-powered Quicksilver Sport into a ROTAX 582-powered Quicksilver Sport would require a check-out and whatever training the examining CFI dictated.

To provide flight training in another category or class of light-sport aircraft [remember that FAA is adding 2 categories: powered parachute and weight-shift-control aircraft (trikes)], the FAA CFI's would have to " receive and log ground and flight training in certain operational areas from an authorized instructor", and " successfully complete a proficiency check from a different authorized instructor". [This is similar to an ultralight instructor applicant who takes instruction from one ultralight instructor, and a written, oral and flight test from a different instructor.]

The authorized instructor who certifies the FAA CFI's proficiency authorizing him/her to provide training for the additional make and model or category and class privileges would endorse the logbook establishing those specific privileges.

The CFI would also have to have at least 5 hours of pilot--in-command time in the specific make and model light-sport aircraft before providing instruction in that aircraft.

Analysis
FAA excludes ultralight instructors from this "simple grandfathering" because they are issued instructor authority under exemptions to part 103, not part 61. A future installment to this page will specifically address what FAA proposes of ultralight instructors who want to have sport pilot instructor privileges.

The FAA proposal works gr eat for existing FAA CFI's. However, very few FAA CFI's have chosen to teach in ultralights even though they could for many years simply apply with one of the associations to be granted that authority with no make/model checkout or minimum flight time.

History reveals problems when CFIs tried to check themselves out in ultralights. This is because ultralights have different flight characteristics than traditional aircraft for which the CFI was trained and tested by FAA. Now all ultralight training programs require a CFI check-out because it has been found essential.

USUA has always required a flight check of FAA CFIs who requested BFI registration. Yet in 20 years of program operation, less than 20% of registered instructors are also CFIs. Those CFIs are USUA members and would be allowed to instruct in any make model of light sport aircraft in which he/she had already logged at least 5 hours.

USUA experience with on and two-place craft weighing less than 992 pounds gross weight indicates that only a category checkout is warranted for instructors. Simply changing make and model within the same category has not proven to be a significant safety hazard. So, USUA can see no reason for FAA to require a specific make/model checkout within a category. A category change (airplane to powered parachute to trike) DOES bring the need for a checkout (with appropriate training to precede the test).

Recommendation
Because FAA is requiring that CFI's pass a flight check and gain 5 hours in make/model before instructing, USUA believes this is a good proposal for existing FAA CFIs. It is recommended that this portion of the proposal be adopted in the final rule.

The proposal makes transition to the new system an absolute breeze for existing FAA CFIs who are also ultralight instructors by exemption. It is recommended that this portion of the proposal be adopted in the final rule.

USUA recommends that, for aircraft up to 992 pounds, the instructor only be required to complete a check-out when changing category, not when moving from one make/model to another within the same category.

MEDICAL

Surely FAA has a challenge to sell the public and especially the downtown airports on the concept of these craft "commonly called ultralights" over cities and into urban airports. To see more about flight over cities and USUAs long-standing view on this, click here.


The First and most important perceived benefit for FAA certificated pilots is the option of flying Light Sport Aircraft with no FAA physical. Acurrent driver's license is proposed to satisfy basic medical fitness. As with FAA pilots who possess an FAA medical, no pilot may fly if a pilot knows or has reason to know of any medical condition that would affect his or her ability to operate a light-sport aircraft, then the pilot would have to refrain from acting as a pilot in command.

Analysis
USUA has compiled data indicating a lack of pilot medical problems as the cause of accidents with ultralight pilots and instructors. Thereis virtually no problem, when considering ultralight flight, and USUA would strongly object to a medical physical requirement for those pilots and instructors.

However, pilot medical data specifically relating to the operationof the significantly heavier and faster aircraft (up to 132 mph), as nowproposed by FAA is not so clear. In any case, USUA has repeatedly statedsince 1988 that there is a need for more reasonable regulation provided for trikesand powered parachutes"and for the use of fat and two-seatultralights for personal recreation by qualified pilots" qualified as inuse of existing ultralight pilot and instructor programs. Regardless, if theproposed medical is successful or not, FAA should pursue regulatoryimprovement for fat and two-seat ultralights for personal recreation by qualifiedpilots as well.

Recommendation
USUA has no objection to FAA's heavy emphasis on driver licens emedicals for pilots. This can benefit those members who cannot pass an FAA physical examination for whatever reason although USUA points out that a certain level of physical ability is required for safe flight. Consistent with our original 1988 petition to FAA, USUA continues to believe that operation of balloons and gliders represent very similar air sport groups, and that the medical requirements to operate those craft should be identical to fat single and two-place ultralights as described in the history section. In any case USUA believes that this single factor should not be the go-or-no-go point for the whole rule proposal, NPRM 11133.

FAA PILOT REQUIREMENTS TO ADD SPORT PILOT PRIVILEGES

Summary
NPRM 11133 proposes that an already FAA certificated private (orbetter) pilot would have sport pilot privileges. However, you must receive and log specific training for any make and model of light-sport aircraft for which you hold a category and class rating and that you haven't piloted. You also have to get a logbook endorsement from the authorized instructor who trained you certifying your proficiency in that make/model.

If a private pilot wants to add category and class privileges for which they do not have an aircraft category or class rating on your private pilot certificate (i.e. powered parachute), they would have to meet the requirements for the addition of those privileges established in an FAA Practical Test Standards or Advisory Circular for each category and class of aircraft. FAA proposes to develop these standards while seeking industry input.

FAA also proposes to establish two new aircraft category and class ratings. They are weight-shift-control [why FAA does not call them trikes,the popular term used worldwide, is unknown] with land and sea class ratings,and powered parachute [no land and sea distinction]. In addition, FAA will develop new training and certification requirements while seeking industry input for these new aircraft ratings at the sport pilot and private pilot levels.

The make/model endorsement requirements, to be written by FAA andto which the CFI must test applicants, are not known. They will be listed in a pilot testing standard that FAA will write later, after seek[ing] industry input. FAA may change the standard in the future as they wish. Essentially, FAA is asking us to trust that their testing standards for each make/model light sport aircraft will be relevant and appropriate.

Analysis
The creation of private pilot levels for trike and poweredparachute may end up being THE huge thing although not much attention is directed this way now. If the practical requirements of sport pilot get too close to the requirements for private, students may go right to private (as is the case now with the Recreational Pilot certificate).

Those who might choose to go to the private certificate, or simply add trike or powered parachute to their existing private certificate, may fly with more than one passenger on a cross-country at night, higher than 10,000 feet ending at a downtown airport. Imagine the 8-place powered parachute being sequenced between traditional airplanes by the air traffic control tower at your downtown airport around 10:00 in the evening. FAA can limit this through the aircraft operating limitations of the aircraft. But such potential is definitely what FAA is proposing to the public in NPRM 11133.

This could be great for those private-and-higher FAA certificated pilots who want to transition to two-seater airplanes, gliders, balloons,powered parachutes, and weight-shift-control aircraft. Remember that sport pilot privileges would not require a 3rd class medical, but only a valid drivers license.

Of course the content of the pilot testing standard"the required knowledge and skill for the specific category"is a huge issue here. These standards do not yet exist and therefore may not be evaluated. The mechanism is simple enough, however. It is basically some training in the aircraft and a CFI logbook endorsement.

Recommendation - FAA pilot requirements to add sport pilot privileges
USUA has no objection to FAA pilot requirements to add sport pilot privileges. For years USUA has expressed concern, however, that requesting such broad privileges could necessitate substantial pilot trainingand aircraft certification standards"more than actually necessary for safe operation of two-seaters flown only day, VFR, and away from congested areas. USUA's petition requested the more limited operating privileges in trade for fewer training requirements.

Surely FAA has a challenge to sell the public and especially the downtown airports on the concept of these craft "commonly called ultralights " over cities and into urban airports.

USUA's petition requested the more limited operating privileges in trade for fewer training requirements. USUA policy continues to relate to the successful operational practices related to pilots of aircraft which have gross weights below 450 kg (992 lb which is similar to the training exemption's 496 lb empty weight plus fuel and occupants) fortwo-place and 300kg (662 lb) for single place, with no more than a 35 knot stall speed.

Recommendation - overflights of cities
Regarding overflights of cities, USUA recommends members be very cautions of supporting the proposal to allow flights over urban areas because it will bring unnecessarily pilot training and aircraft certification standards to those who are willing to remain clear of cities and downtown airports.

Recommendation - make/model specific checkout requirements.
Regarding make/model specific checkout requirements, twenty years of experience with operation of such craft (ultralights) show no significant need for a make/model checkout between aircraft of the same category and class (i.e. airplane with wheels vs. airplane on floats). Therefore USUA recommends that you object to make/model checkout within the same category and class aircraft "at least for those craft that match the existing world of ultralights.

For further reading: