James E. deMasi 

20343 Allegro Shores Lane 

Humble, Texas 77346 

L ; ; 

June 20, 2012 

SUBJECT: Docket #FAA-2012-Q350 

Dodet Management Facility 

ATIN: Comments on Docket No. FAA 2012-0350 

U.S. Department of Transportation 

1200 New Jersey Avenue SE Room W12-140 

Washington, D. C. 20590 

Ladies and Gentlemen, 

I want to comment on the joint EAA/AOPA Medical Exemption Request to enable pilots to fly higher horsepower 

aircraft, up to 180 hp, with a driver's license, rather than a Class 3 FAA medical. I think this is a wonderful idea. I agree 

with 'f:AA's and AOPA's contention that this exemption will reduce "red tape" and expense for both the pilots and the 

FAA. I think another benefit will be "improved safety", even without the newly proposed medical training. Many pilots 

will move away from old, amateur built, and S-LSA aircraft into heavier, more rugged standard category airplanes. 

I have been a private pilot since 1961, but stopped flying in the late 1980s when I developed a health problem. 

Although my problem was non-life threatening, and did not inhibit me from any other activities, the medical folks 

indicated I would have difficulty obtaining a Class 3 medical and that likely when I did get a medical, it would only be 

good for a very limited period of time, maybe 6 months or a year, significantly less than the normal 3 years. Rather than 

go through all the extra medical red-tape and out of pocket costs required by FAA, I elected to give up my flying hobby. 

But, when light sport came along, I began flying again in 2004. Thank you for your good hard work in getting the light 

sport program initiated. I have logged 167 hours since I re-started flying in 2004. With insurance and other expenses, I 

estimate that I have spent more than $20,000 since I re-started flying in 2004. I believe this is good for General Aviation, 

airports, tax revenue, and the aviation industry in general. 

Presently, pilots flying airplanes (not kites, trikes, etc.) as Light Sport Pilots, utilizing their driver's license as proof 

of medical, are limited to basically three classes of airplanes that meet the 1320 pound maximum gross weight load 

limit: old airplanes, amateur built E-LSA airplanes, and new, factory built S-LSA airplanes. While each of these aircraft 

types has certain advantages, each also has limitations that impact safety. Let me explain. 

All of my flying since 2004 has been in airplanes that meet the 1320 pound maximum gross weight load limit. All 

of my flying is for fun. I enjoy taking my grandchildren and others out for a ride or for a "$100 hamburger''. There are 
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lots of neat places to go in this area. Like all of the pilots I know, I never fly if I am not feeling up to par 100%. Since 

2004, I have logged 54 hours in "old" airplanes, 40 hours in "amateur built" E-LSA airplanes, and 73 hours in "new, 

factory built, S-LSA" aircraft. Here are some of the safety related observations I have made. 

Old Airplanes -I have flown three different Ercoupes, and a Taylorcraft, all built before 1950. Old airplanes are 

like old cars; they have a lot of problems that one can live with, but they are old. The list includes old wiring, old circuit 

breakers, dents in the aluminum, dings in the prop, stains and cracks in the Plexiglas windows, bent moldings, weak 

brakes, worn interiors, marginal radios and transponders, oil leaks, struts that seep a bit of oil, heater controls that do 

not turn off the heater, small seats, no 12-volt connection for a portable GPS, and the list goes on. You have to assume 

the structure has been checked by the A&E and A&P at annual. Additionally, all the old airplanes I have flown have 

limited useful loads that require flying with less than full tanks if you take two reasonably sized people up. The 

Taylorcraft has no electrical system, so we hand prop the airplane, there is no radio, so we use a handheld radio in and 

out of a pilot controlled field. One of the Ercoupes has no shoulder harness (lap belt only). Another developed a 

plugged fuel overflow line while in flight; another the fuel pump began to fail in flight as it wore out. Electrical problems 

with the radios and transponders are not unusual. Sometimes these electrical problems have been the result of old 

avionics, sometimes worn out "push to talk" buttons, sometimes old or poorly shielded wiring. The brakes on all of 

these old airplanes are so weak, we typically put one wheel in the grass to hold the airplane to do the run-up. 

Amateur Built E-LSA -I have flown an Aventura AV II, and with a partner, owned a Slipstream Geneses for a 

short time. Both were built by others, not me, and maintained by others. The Aventura had a Rotax 100 hp engine; the 

Geneses had a MZ 202 two-cycle engine. Both had geared props, working off the high rpm engines. Each amateur built 

airplane is different from all the others. The Geneses we owned had neither fuel sumps nor drains in the fuel tanks, and 

we encountered fuel problems and plugged fuel filters with this airplane. Construction and maintenance are questions 

on these airplanes, especially for "non-builders" that may become second or third owners. There is no quality control by 

anybody other than the builder. We encountered two different gear case problems where gear oil was seeping out of 

first the front seal, and then the back seal around the prop. The radios were marginal in these airplanes, and in one the 

wiring had not been shielded properly, so we had a lot of noise in the headsets. We also encountered problems in flight 

with aircraft construction with trim and doors. Needless to say, my partner and I got rid of the Geneses after a short 

period of ownership. 

Let me add a word about handheld radios. I have one, and use it quite a bit, but not in flight if I can help it. 

They work great on the ground. However, in flight, I have a great deal of difficulty hearing the transmissions from others 

in the noisy cockpit. My transmissions seem to be heard fine by others if I am not too far away. I consider my handheld 

a backup tool, if needed, but I do not depend upon it as a primary means of communication. The cockpits in both old 

airplanes and in amateur built airplanes that I have flown are noisy. So, in old airplanes and amateur built airplanes, one 

needs a good radio installed with good wiring and a good antenna so communications through the headset are clear and 

understood by all. And here, around the Houston area, as in many other areas, a good transponder is also essential. A 

good radio and a good transponder are safety features. Of course, good radios and good transponders add empty 

weight to an airplane, which reduces useful load. The 1320 pound maximum gross weight is already very limiting on 

useful load on many airplanes! 

New, factory built, 5-LSA airplanes- I have logged time in a Legend Cub (100 hp Cont. engine), a Tecnam P-92 

(100 hp Rotax), an Allegro (80 hp Rotax), Cessna Skycatcher (100 hp Cont.), a Flight Design CTLS (100 hp Rotax), and took 

a demonstration ride in a Sport Cruiser (100 hp Rotax). I have also ridden with another pilot in an Evector (100 hp 

Rotax). All of these, except the Legend Cub, were manufactured outside the USA. Each of these airplanes has some very 

nice features and advantages. They are all new; they have nice radios and transponders, good brakes, nice interiors, 
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good visibility and many other nice features. However, they have some shortcomings. The Legend Cub and the 

Skycatcher with the Continental engines have limited useful loads. The others, with the Rotax engines and geared props 

require one to pull the prop through several blades to "girgle" the oil before checking the oil on pre-flight. Most only 

have a small door for checking the oil on preflight, and only a limited view of engine mounts, spark plug wires, bird 

nests, oil leaks or other potential problems inside the cowling on preflight. Some of the new airplanes have 

cumbersome check lists that contain checks of equipment that may not be installed on a particular airplane. These new 

S-LSAs are very light, and seem to me to be less rugged in construction than standard category airplanes. I am aware of 

3 different instances of landing gear failures on 3 different S-LSAs here in the Houston area, and one instance of a door 

popping open and being damaged in flight. When one is solo with fuel down to an hour or two in one of these airplanes, 

the gross weight may be less than 1000 pounds, and the very light airplanes are very sensitive to light wind puffs. Also, 

some of these airplanes contain glass panels that seem to me to be more complex than one needs to fly as a light sport 

pilot (daytime VFR). It takes several hours of flight and ground time to become comfortable with some of the complex 

glass panels and this can be a significant safety issue with old guys or low time pilots. And the fancy multiple-screens 

may draw the pilot's eye away from looking out the window. 

I want to comment also on cost and availability. Here in the Houston area over the past few years there have 

been several old airplanes that meet light sport requirements and several S-LSA aircraft available for rent at different 

airports. However, I have noticed that availability seems to "come and go" at various Fixed Base Operators and Flight 

Schools. No airport has had more than one operator offering LSA airplanes for rent, nor has anybody had more than one 

of any one type of LSA airplane for rent. All of the airplanes are different. If, for example, one rents a Tecnam at 

Ellington Field (EFD), and the airplane becomes unavailable for some reason, and the pilot wants to continue to fly, he 

may go to Pearland (LVJ) and rent an Allegro, or to West Houston (IWS) and rent an Evector, or to LaPorte (T-41) and 

rent an old Ercoupe or a Legend Cub. The airplanes are different, instructors are different, each airport is different, and 

all of these availability, airplane and location factors impact safety and cost. Meanwhile, all of these airports and several 

others in the area offer several Cessna 150s, 172s, Piper Warriors, and many other more familiar airplanes for rent. I 

think that pilots, flying the same type of airplane improve safety, especially with experienced pilots that may have 'been 

flying a certain type of airplane for many years. Conversely, changing airplane types frequently may have a negative 

effect on safety. 

Cost of renting all of the old airplanes I mentioned above have been running in the $85-90 per hour range in this 

area; the new, S-LSA airplanes rent in this area for about $100 an hour; and I have not found anybody renting any 

amateur built E-LSAs. Availability of standard category, fixed gear airplanes, up to 180 hp, is much better than LSAs in 

this area with rental costs running in the $80-115 per hour range. 

Aircraft ownership is another factor that I continue to consider. I have owned two airplanes, and some of the 

other pilots I fly with have also owned airplanes. Since we are flying as light sport pilots, we have the same three 

choices for ownership as we do for rental: old airplanes, amateur built airplanes, or new S-LSAs. We tried the second 

owner idea of an amateur built airplane, and it did not work out for us. Spending $100,000+ on a new or relatively new 

S-LSA does not appeal to us, due to many of the factors I outline above. And buying an old, pre-1950 airplane with 

limited useful load, marginal radios and transponders and weak brakes does not appeal to us either. If you take a look at 

Barnstormers on line or Trade-A-Plane, you will notice that there are plenty of nice, relatively low time well equipped 

airplanes up to 180 hp for sale at prices well below $50,000 that solve all of the problems I have mentioned. 
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So, the above comments summarize what I consider to be safety related concerns with the present airplanes 

available to light sport pilots. I have also commented on cost and availability. Your initiative to allow light sport pilots to 

fly other airplanes, including the Cessna 150, 172, Piper Warrior and Archer, and other fixed gear aircraft up to 180 hp 

seems like an easy fix to all of the above problems. 

In summary, by extending the medical exemption to include airplanes up to 180 hp, I believe with the larger 

more rugged standard category airplanes as compared to the LSAs in this area: safety will be improved, costs will be 

about the same, aircraft availability will be better, airplanes will be newer, airplanes will be better equipped (with good 

radios and transponders), airplanes will be in mechanically better shape, airplanes will be much more user friendly (easy 

panel, good brakes, easy check lists, cowlings that open fully, easier to handle in moderate wind, etc.), and the airplanes 

will be more familiar to the pilot population. With FAA's approval of the proposed medical exemption I believe that all 

of these considerations will lead to improved safety, more people flying, increased cash flow to the aviation industry, 

increased tax revenues, and everybody wins. 

f encourage you folks at FAA to move this proposal forward quickly, and give it a "thumbs up!" Good luck with 

the new initiative. 

Yours very truly,