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 ofTransportation 1200 NewJersey Avenue SE Room W12-140 Washington, D. C. 20590

Ladies and Gentlemen, Iwantto comment on thejoint EAA/AOPA Medical Exemption Request to enable pilots tofly higher horsepower aircraft, up to 180 hp, with a driver's license, ratherthan a Class 3 FAA medical. Ithinkthis is awonderful idea. I agree with'f:AA's and AOPA's contention thatthis exemption will reduce "red tape" and expense for both the pilots and the FAA. I think another benefit will be "improved safety", even withoutthe newly proposed medical training. Many pilots will move awayfrom old, amateur built, and S-LSA aircraft into heavier, more rugged standard category airplanes. I have been a private pilotsince 1961, butstopped 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 otheractivities, the medical folks indicated Iwould have difficultyobtaining a Class 3 medical and that likely when I did geta medical, itwould only be goodfor avery limited period oftime, maybe 6 months orayear, significantly less than the normal 3 years. Rather than go through all the extra medical red-tape and outof pocket costs required by FAA, I elected to give up myflying hobby. But, when lightsport came along, I began flying again in 2004. Thank you foryourgood hard work in gettingthe light sport program initiated. I have logged 167 hours since I re-started flying in 2004. With insurance and otherexpenses, 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, utilizingtheir driver's license as proof ofmedical, are limited to basically three classes ofairplanes that meetthe 1320 pound maximum gross weight load limit: old airplanes, amateur built E-LSA airplanes, and new, factory built S-LSA airplanes. While each ofthese aircraft types has certain advantages, each also has limitationsthat impact safety. Let me explain. All ofmyflying since 2004 has been in airplanes that meetthe 1320 pound maximum gross weight load limit. All ofmyflying is forfun. I enjoytaking mygrandchildren and others outfor a ride orfor a "$100 hamburger''. There are

### -2- lots of neat places to go in this area. Like all ofthe pilots I know, I never fly if I am notfeeling upto 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 ofthe safety related observations I have made. Old Airplanes -I have flown three different Ercoupes, and aTaylorcraft, all built before 1950. Old airplanes are like old cars; they have a lot ofproblems that one can live with, butthey 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 ofoil, heater controls that do notturn offthe heater, small seats, no 12-voltconnection 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 atannual. Additionally, all the old airplanes I have flown have limited useful loads that require flying with less than full tanks ifyou take two reasonably sized people up. The Taylorcraft has no electrical system, so we hand propthe airplane, there is no radio, so we use a handheld radio in and outofa pilot controlled field. One ofthe Ercoupes has no shoulder harness (lap beltonly). Anotherdeveloped a plugged fuel overflow line while in flight; anotherthe fuel pump began tofail in flight as itwore out. Electrical problems with the radios and transponders are not unusual. Sometimes these electrical problems have been the result ofold avionics, sometimes worn out "push totalk" buttons, sometimes old or poorly shielded wiring. The brakes on all of these old airplanes are so weak, we typically putone 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 shorttime. Both were built byothers, not me, and maintained byothers. The Aventura had a Rotax 100 hp engine; the Geneses had a MZ 202 two-cycle engine. Both had geared props, workingoffthe high rpm engines. Each amateur built airplane is differentfrom all the others. The Geneses we owned had neitherfuel 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 orthird owners. There is no qualitycontrol by anybodyotherthan the builder. We encountered two differentgear case problems where gear oil was seeping out of firstthe 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 Igot rid ofthe Geneses aftera short period ofownership. Let me add aword about handheld radios. I have one, and use itquite a bit, but not in flight ifI can help it. They work great on the ground. However, in flight, I have agreat deal ofdifficulty hearingthe transmissions from others in the noisy cockpit. Mytransmissions seem to be heard fine by others if I am nottoo faraway. I consider my handheld a backup tool, if needed, but I do not depend upon itas a primary means ofcommunication. 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 agood radio installed with good wiring and agood antenna so communications through the headset are clear and understood by all. And here, around the Houston area, as in many otherareas, a good transponder is also essential. A good radio and agood transponder are safetyfeatures. 

### Ofcourse, good radios and good transponders add empty weightto an airplane, which reduces useful load. The 1320 pound maximum gross weight is alreadyvery limiting on useful load on manyairplanes! New,factory built, 5-LSA airplanes- I have logged time in a Legend Cub (100 hp Cont. engine), aTecnam 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 ofthese, exceptthe Legend Cub, were manufactured outside the USA. Each ofthese airplanes has some very nice features and advantages. They are all new; they have nice radios and transponders, good brakes, nice interiors,-3- goodvisibility and manyother 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 doorfor checking the oil on preflight, and onlya limitedview ofengine mounts, spark plug wires, bird nests, oil leaks orother potential problems inside the cowling on preflight. Some ofthe new airplanes have cumbersome check lists that contain checks ofequipmentthat 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 oflanding gear failures on 3 differentS-LSAs here in the Houston area, and one instance ofa door popping open and being damaged in flight. When one is solo with fuel down to an hourortwo in one ofthese airplanes, the gross weight may be less than 1000 pounds, and the very light airplanes are very sensitive to lightwind puffs. Also, some ofthese airplanes contain glass panels that seem to me to be morecomplex than one needs to flyas a lightsport pilot (daytime VFR). Ittakes several hours offlight and ground time to become comfortable with some ofthe complex glass panels and this can be a significant safety issue with old guys or lowtime pilots. And the fancy multiple-screens may drawthe pilot's eye awayfrom looking outthe window. Iwantto comment also on cost and availability. Here in the Houston area overthe past fewyears there have been several old airplanes that meet light sport requirements and several S-LSA aircraft available for rent atdifferent airports. However, I have noticed that availability seems to "come and go" atvarious Fixed Base Operatorsand Flight Schools. No airport has had morethan one operatoroffering LSA airplanes for rent, nor has anybody had more than one ofany one type of LSA airplane for rent. All ofthe airplanes are different. If, for example, one rents aTecnam at Ellington Field (EFD), and the airplane becomes unavailable forsome reason, and the pilotwants to continue to fly, he maygo to Pearland (LVJ) and rent an Allegro, orto West Houston (IWS) and rentan Evector, orto LaPorte (T-41) and rent an old Ercoupe ora Legend Cub. The airplanes are different, instructors are different, each airport is different, and all ofthese availability, airplane and location factors impact safety and cost. Meanwhile, all ofthese airports and several others in the area offerseveral Cessna 150s, 172s, Piper Warriors, and many other more familiar airplanes for rent. I thinkthat pilots, flying the same type ofairplane improve safety, especiallywith experienced pilots that may have 'been flying a certain type ofairplane for manyyears. Conversely, changing airplane types frequently may have a negative effect on safety. Cost of renting all ofthe 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 notfound anybody renting any 

### amateur built E-LSAs. Availability ofstandard category, fixed gear airplanes, upto 180 hp, is much betterthan LSAs in this area with rental costs running in the $80-115 per hour range. Aircraft ownership is anotherfactorthat I continueto consider. I have owned two airplanes, and some ofthe other pilots Ifly 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 ofan amateur built airplane, and itdid not work outfor us. Spending $100,000+ on a newor relatively new S-LSA does notappeal to us, due to many ofthe factors I outline above. And buyingan old, pre-1950 airplane with limited useful load, marginal radios and transponders and weak brakes does notappeal to us either. Ifyou take a look at Barnstormers on line orTrade-A-Plane, you will notice thatthere are plenty of nice, relatively lowtime well equipped airplanes up to 180 hpforsale at prices well below $50,000 that solve all ofthe problems I have mentioned.-4- 

### 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 initiativeto allow light sport pilots to fly otherairplanes, including the Cessna 150, 172, Piper Warriorand Archer, and other fixed 

### gear aircraft up to 180 hp seems like an easy fix to all ofthe above problems. In summary, by extendingthe medical exemption to include airplanes upto 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 aboutthe same, aircraftavailability will be better, airplanes will 

### be newer, airplanes will 

### be betterequipped (with good radios 

### and transponders), airplanes will be in mechanically bettershape, airplanes will be much more user friendly (easy panel, good brakes, easy check lists, cowlings thatopen fully, easierto handle in moderate wind, 

### etc.), and the airplanes will be more familiar

### tothe pilot population. With FAA's approval ofthe proposed medical exemption I believe that all ofthese considerations will lead to improved safety, more people flying, increased cash flowto 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 verytruly,