Number range CHAPTERResponse to FAA-2007-29015: Certification of
Aircraft and Airmen for the operation of Light-Sport Aircraft;
Modification to Rules for Sport Pilots and Flight Instructors with a
Sport Pilot Rating.

I am the manager Of Chesapeake Sport Pilot, the largest flight school
dedicated to light sport instruction in the country. Since its inception
in the winter of 2006/07 I have participated in the growth of this
flight school from one plane and one instructor to a fleet of seven
aircraft with 20 instructors, more than 70 active primary students, and
several dozen renters and pilots working on flight reviews. Growth of
our industry has been phenomenal due in large part to the hard work and
foresight of the FAA in creating a regulatory structure suitable for
revitalizing grass roots general aviation.

This NPRM is yet another excellent step forward by the FAA. I strongly
applaud the FAA's efforts in this NPRM on the following points:

> 1.) Creating a new training and certification framework which closely
> parallels that for private and commercial pilots hence making the
> rules simpler for a flight instructor to understand and correctly
> follow.
>
> *Comment:* The current training structure is confusing to traditional
> flight instructors. By brining this sport pilot training framework
> into a system that parallels that for other ratings, more instructors
> will be willing to instruct on the sport level and less mistakes will
> be made by instructors confused over training procedures and
> regulatory compliance.
>
> 2\) Doing away with the need for sport pilots to carry their log books
> with them.
>
> *Comment:* This an unnecessary burden on pilots, especially those with
> many flight hours now exercising sport pilot privileges. One CFI, a
> highly accomplished pilot and retired FAA DPE on my staff who is
> exercising sport pilot privileges, has so many log books he carries
> them around in a suit case too big to fit in many of our LSAs!
>
> 3\) Instituting the quality assurance and quality control inherent
> with DPE check rides to obtain category and class privileges.
>
> *Comment:* While my flight school is lucky enough to have a retired
> FAA DPE performing our category and class transition exams, most
> flight schools are not so privileged. Under the current system, in
> many cases, a light sport instructor, who has less than 200 hours and
> who is untrained in examination procedures may be performing check
> rides. This does not ensure the quality control and assurance which
> the general aviation community and public at large depends upon the
> FAA to provide. Bringing check rides back under the auspices of fully
> trained and certified FAA designated examiner will reinstate such
> quality control and assurance.
>
> 4\) Doing away with sets:
>
> *Comment:* Sets are overly confusing to students and instructors. The
> original goal of the set system, which was to ensure pilots have
> training in aircraft with different flight characteristics, is already
> accomplished through category and class ratings and tail wheel
> endorsements. Sets are redundant and only serve to overly complicate
> the training system.
>
> 5\) Doing away with the five hours of flight time within set required
> of a flight instructor prior to providing dual to a sport pilot
> candidate.
>
> *Comment:* While some instructors may require several hours of flight
> time in a particular LSA before being competent to instruct in it,
> this is a decision which should be left to the flight school, the
> insurance company, and the instructor. We have found that many of the
> instructors we have hired have thousands of hours in Cubs and Champs.
> For them instructing in a tricycle gear LSA is a piece of cake and
> requiring 5 hours in set is ludicrous. Adding to the silliness of this
> situation, the 5 hours is only required if the student declares he
> wished to be a light sport student rather than a private pilot
> student. This requirement simply makes no sense and needs to go away.
>
> 6\) Standardizing endorsements between students and fully rated sport
> pilots.
>
> *Comment:* One problem we have is that our check rides take place at a
> towered field. If I endorse a student for class D airspace and he
> passes the exam, he cannot come home because a separate endorsement is
> required of a rated sport pilot to operate in class D airspace. While
> I have dealt with this problem by combining the student and rated
> pilot endorsements into one and signing them off together, it would be
> much more helpful if the FAA would address this problem themselves in
> the wording provided in AC 61-65.
>
> 7\) Allowing light sport aircraft to be used in part 141 courses
> without a special waver.
>
> Comment: Some of the LSA trainers, such as the Tecnams we fly, are
> truly superb training aircraft. I would have no qualms taking a
> student from sport through instrument using such a plane. Large part
> 141 schools need a viable alternative to the gas guzzling, 52 year old
> Cessna 172 design if the United Sates is going to continue to be the
> world leader in training high quality airline pilots. LSAs are the
> logical future of our industry.
>
> 8\) Providing leniency to the altitude restriction in mountainous
> areas.
>
> *Comment:* Flight schools located in high altitude areas deserve some
> sort of leniency to the 10,000\' MSL altitude restriction.

Despite these excellent steps by the FAA, I believe there is still room
for improvement. The following are my comments on additional ways to
improve the light sport rules:

1.) Credit for training given by a flight instructor holing a sport
pilot rating.

> Sport pilot is not only a recreational pilot certificate but is seen
> my most students as a stepping stone rating towards additional
> advanced aircraft ratings. As such, it is imperative that all training
> given to a student while obtaining a sport pilot rating count towards
> additional ratings. However, because of the way the regulations are
> currently worded, training provided to a student seeking a sport pilot
> certificate may or may not count towards higher certificates depending
> upon the type of flight instructor rating held by his/her instructor.
> A student learning to be a sport pilot under a subpart K instructor
> will need to repeat much of his training when adding on private
> privileges, where a student learning to be a sport pilot under a
> subpart H instructor will be fully credited for his previous training.
> This is despite the fact that they received identical training each
> under an instructor properly rated to give that training!
>
> Equal training needs to receive equal credit. Flight schools, such as
> mine will be reluctant to train and hire subpart K instructors (those
> with a sport pilot rating) if we have to be concerned with a sport
> pilot graduate coming back 10 years later with a 2000 hours under
> his/her belt wishing to add on a higher rating only to find he/she
> needs to repeat his/her primary training.
>
> The subpart K instructor is a wonderful rating developed by the FAA
> under the sport pilot rule. Finally, high time and experienced private
> pilots, with a willingness, desire, and ability to teach someone to
> fly a plane, can become a flight instructor without \$20K worth of
> instrument and commercial prerequisites. However, the wording of these
> rules needs to be tweaked to address the problem outlined above.

2.) Standardizing the privileges, limitations, and endorsements required
of a student pilot.

> A student pilot is a student pilot regardless of rating sought by the
> student pilot. The same skill sets are required to solo a plane
> regardless of whether or not the student intends to obtain a private
> pilot certificate or sport pilot certificate. The FAA recognizes this
> in that FAR §61.67 applies to all student pilots regardless of
> intended rating. However, under the current rules, flight instructors
> are responsible for somehow determining which rating, sport or
> private, the student will ultimately take the exam for. Student pilots
> change their minds about which plane to fly, which instructor to fly
> with, and even which school to attend. They are no more decisive about
> which rating to complete first than any of these other things. Despite
> this, the flight instructor is responsible for somehow forecasting
> this and differentiating for different restrictions and endorsements
> such as:

a\) Vh endorsement for sport pilot students

b\) Class D and C endorsements for sport pilot students

c\) Instrument training prior to cross country for private pilot
students

Additionally, under the current rules, the Chief Flight Instructor is
expected to forecast the student's future intentions when deciding
whether or not to assign the student to a subpart K instructor or a
subpart H instructor.

> I do not believe that it was the FAA\'s intention to create two
> different types of student pilots when they created the sport pilot
> rule. However, as the rule is currently written, such exists. To
> eliminate this confusion, I suggest the following:
>
> a\) Do away with the Vh endorsement. Private pilots have been
> transitioning for years between these two speed ranges without such an
> endorsement. Have we really seen an accident rate that justifies a
> need for such an additional endorsement?

b\) Require D and C endorsements for all student pilots.

> c\) Eliminate the instrument training requirement in FAR §61.93(d).
> Student pilots are limited by FAR §61.89 to flight visibility of at
> least 3sm and I personally don\'t know any instructors who would
> endorse a student to leave the pattern in anything less than 6sm.
> Instrument training is not practical in terms of student pilot safety
> and it places an unnecessary burden on the sport pilot community for
> all the reasons listed below.
>
> d\) Allow a subpart K instructor to train a \"student pilot\" with out
> the differentiation of \"a student pilot seeking a sport pilot
> certificate.\"

3\) 1 Hour of Instrument Time

> I strongly believe that instrument flight training should be a
> decision left to the flight instructor to be based upon the student,
> aircraft, and situation in general. My reasoning for such is as
> follows:

a\)

> Many LSA's do not have the necessary instruments in which to do the
> proposed flight training. While LSA's typically have an airspeed
> indicator and altimeter, some don't have a compass and most don't have
> turn coordinators (the basic devices necessary to accomplish
> rudimentary instrument flight). Installing a typical turn coordinator
> requires increasing the total weight of the machine. At some point,
> based on the weight limitations of LSA's, a reduction in fuel capacity
> might be needed to compensate for the increased weight required to
> sustain the necessary instruments for LSA instrument flight. I can't
> see how reducing an airplane's fuel capacity to sustain these
> instruments enhances safety giving the low likelihood of sport pilots
> even needing basic instrument skills.
>
> b\) Since they are designed for VFR flying, some LSAs, such as our Sky
> Arrows, have such incredible visibility, there is no way to properly
> blind a student for such training. (See attachment.)
>
> c\) Light sport students by in large are not interested in flying in
> low visibility conditions. They are flying for fun, and flying when
> you are struggling to see out of the plane is not fun to them.
> Teaching them that they have not been trained for such and to land in
> poor weather is much more prudent.
>
> d\) Subpart K instructors will themselves only have 1 hour of
> instrument training which is not enough to be capable of teaching
> another person effectively in the use of instruments.
>
> e\) Unlike the risks to life, limb and property with a private pilot
> operating an airplane capable of carrying several passengers, sport
> pilots carry no more than one passenger. They are also prohibited from
> flying at night and during less than 3miles visibility, both of which
> make it less likely that a sport pilot will inadvertently fly into
> instrument conditions. As a result, the NPRM's proposed instrument
> training requirement will be much more of a burden than an asset to
> the safety of the sport pilot community.

4\. Commercial and charity operations

> It is silly to prohibit use of LSAs in commercial operations such as
> sight seeing and photography. Limitations such as these should be
> placed upon the pilot, not the aircraft. A flight by a high time
> commercial pilot holding a second class medical taking a photographer
> aloft certainly has less risk involved than a flight by a 150 hour
> Subpart K instructor with no medical taking a student pilot up for his
> first landing lesson.
>
> Along those same lines, there is no inherent danger in an
> appropriately rated pilot using an LSA as part of a charity event.
> This rule only punishes those who least deserve it, the charities.
> Keep the limitation on the spot pilot certificate, but bring some
> common sense to the limitations on sport aircraft themselves.

5\. Corrections and clarifications

> a\) Please correct the AIM 3-2-3 (b)3 which states that sport pilots
> are not allowed in class B airspace
>
> b\) Please clarify whether or not an endorsement is required for sport
> pilot to operate in a TRSA and the Washington DC ADIZ. If \"yes\" to
> either of these, please reflect such in AC 61-65. Please be sure your
> TRSA clarification reflects the non-mandatory nature of TRSA services.
>
> c\) Please add the endorsement wording to AC 61-65 for the endorsement
> required by FAR §61.39a(a)(6)(iii) showing that the flight instructor
> has gone over the areas found deficient on the knowledge exam.

Thank you for your hard work and great effort at making sport pilot an
even better rule than it currently is. I look forward to the regulatory
improvements sure to come about through this proposal and comment
process.

Helen Woods

Manager and Chief Flight Instructor

Chesapeake Sport Pilot, LLC

Stevensville, MD 21666

\(410\) 490-1424

<Helen@ChesapeakeSportPilot.com>