To whom it may concern,

I have been advised that the LODA (Letter of Deviation Authority) process is not available at this time for Experimental Light-Sport aircraft. Therefore, I am requesting an exemption from the rule that has terminated the use of my aircraft for training purposes. This rule that allowed training expired on January 31 st , 2010. This has created a very large problem for the lighter end of Light-sport training in our area. This has severely restricted any options for any of the pilots that want training in the lighter aircraft design. Attached is a complete description of the proposed operation and justification that establishes a level of safety equivalent to that provided under the regulations for the exemption requested. The type of training is described along with a list of the aircraft to be used, the instructor qualifications, and an appropriate training course outline.

My name is Dahl Cooper. I would like to relate to you my history, experience, the type of aircraft that I use, the training course that I teach (and have been for years). I first started in aviation 24 years ago in 1986 flying ultralight aircraft. Back then, there was not much in the way of training in ultralight aircraft ( and of course, part 103 says you are not required to have any training, although that’s not such a great idea). I found out right away I needed a lot more training. I ended up going to Las Vegas and taking some training from an instructor named Don (Hawk) Wyatt. He was a very good pilot and instructor. In 1990, I tested and received my BFI (Basic Flight Instructor) certificate through USUA (United States Ultralight Association). I then started instructing part time until about 1992 when I quit my real job and started my fun job of full time instructing at The Ultralight Strip (4AZ8) which my very good friend and I opened in 1992 and built literally from the ground up. We started 100% in ultralights and eventually converted every craft on our field (currently about 35 aircraft) to Light-Sport. During the years of instructing in ultralight aircraft, I endorsed for certification several hundred ultralight pilots. I then tested and received my Sport Pilot CFI in 2006. I have taught nothing but Light-Sport since then. Many of my students from both ultralight and Light-Sport have since gone on to become private pilots and a couple have even become CFI’s. I am very proud of the program that I teach and I feel I teach it well. My #1 priority is safety before all else. One of the big safety issues facing the Light-Sport community is a “general aviation” pilot or commercial pilot jumping into one of the high drag machines without proper transition training. In a related story, in 2008, one of our pilots, Tom, sold a single place Light-Sport to someone in Oklahoma. They hired a ferry pilot to fly it from our field to Oklahoma. I asked the ferry pilot about his experience in our type of aircraft. He responded that he was an airline pilot and ferries Cessnas and Pipers all over the country, but no experience in this type. He declined any transition training. I refused to let him take off from our field and simply told him I didn’t want to be held responsible if he killed himself at our place. He respected my decision and Tom flew the aircraft to Marana Regional Airport for him to take from there. The pilot did ask if there was anything he should know about the this type of aircraft and I advised him until he learns about drag, he should use power at all time-even on approaches. He took off from Marana and died 45 minutes later at the Benson airport in the pattern when he entered a stall/spin and didn’t recover.I train a lot of these type of pilots and they are always surprised at how quickly these aircraft run out of energy. I usually have to save most of their landings for the first hour of their training. This type of training cannot be achieved with the faster fiberglass Light-Sport aircraft. I’ve been doing this a long time and have learned a lot through the years, enhancing the teaching process tremendously. The type of aircraft that I use for instruction are of low mass/high drag configuration. We are definitely on the lighter and slower end of Light-Sport. It’s not likely to find any of the fiberglass 120-130 mph machines at our airpark. We have two 1900' dirt runways. The perfect park for our lighter “ultralight-type” aircraft. The aircraft that I currently use for dual instruction is a Rans S12XL (N229DC). Typical cruise is 65-75 mph, minimum stall is 45 mph, and top speed is about 85-90 mph, VNE is 100 mph. This aircraft is an ideal machine for teaching the slower and medium speeds encountered in the typical lighter end of Light-Sport aviation. I use a single seat Quicksilver Sport (N352PK) for my student solo and solo work. My students complete their solo work in the Quicksilver Sport and then do their practical in the Rans S12XL. We bring down a DPE from Buckeye, Arizona to do the practical. The name of the examiner is Terry Brandt. He was my examiner for both my Sport-Pilot and Sport-Pilot CFI. He as given me tremendous guidance and is my guru whenever I can’t figure out how to interpret the regulations. In my opinion, he is also one of the best instructors I have

ever encountered. While flying ultralights and Light-Sport, I have accrued over 11,000 hours-the majority of it giving flight instruction. The single biggest thing I enjoy about the Sport pilot program is the structure of the training. In the ultralight program there really wasn’t a real structure for the instructors to teach. A lot of it was up to the instructor to certify the student whenever the instructor felt like it. There were a lot of instructors, in my opinion, that really should not have been instructing. The Sport pilot program is very precise as to what is expected from the student. The ground school materials that I use are from Gleim. As far as my aircraft are concerned, all of the 100 hour inspections and condition inspections are carried out by either an A&P mechanic or a Light-sport repairman. My aircraft are kept well maintained. Also, my aircraft were previously granted the training deviation under FAR 91.319(e). As you have read, I am not asking for an exemption on any aircraft that have not already been in the Light-Sport training environment. I am not trying to start a new business-my business has been in place for more than 20 years. The “low mass/high drag” type of aircraft that we operate simply have not been produced in the SLSA category in any kind of numbers to help us. To my knowledge, there are only 2 manufacturers that have produced an aircraft that would come close to what we do. The aircraft mentioned are the CGS Hawk and the M-squared. I am very familiar with them and have in fact built a few of them. Nice aircraft, but very light-duty compared to the Rans that I use. In the training environment that we are in, I don’t believe they would hold up to the rigors of how much training that I do and on top of all that they only come equipped with a 2-stroke engine. I don’t know if you’ve had any experience with 2-strokes on aircraft before, but I will tell you it makes life exciting (not in the way I’d like to be excited). Most people won’t even use them on a lawn mower. To date I have flown approximately 9000 hours in 2-stroke equipped aircraft and have had over 50 engine failures-remember that I am in the training environment. Most of those failures occurredwith a student on board. I have always strived to fly in a manner in which I would have a safe place to land and have been very successful. Very rarely have I bent any aircraft in which I have experienced an engine failure but the odds some day can and will catch up. My Rans S-12 is equipped with the Rotax 912S 4-stroke engine. I have over 2000 hours flying 4-stroke equipped aircraft and have not experienced any major engine problems at any time. The safety factor here just can’t be emphasized enough. I feel as if I use these other aircraft with a 2-stroke, I would be stepping back 20 years. I have worked a long time trying to get away from the 2-strokes and finally achieved success with the 4-stroke. As I have stated, my number one priority in my training program has always been safety, safety, safety. In my career of flying and instruction, I have been through all the years in ultralights, given flight instruction in ultralights and then when the Light-sport rule came out, I started instructing Light-sport. I was a little worried that the simple world of ultralights would forever be changed. In a way, I was right. The ultralight instructor program was terminated and I was required to upgrade to the Sport CFI. As I have stated before, I am grateful for the structure of the program and I am one of the instructors out there that really do this for a living. Unfortunately, now there is a kink in all this. My training program has now come to a screeching halt as of January 31 st , 2010. All the years of building the business and building my reputation has now come to where I have to tell people that I cannot help them. I have now lost a major part of my income and the referrals from previous students and pilots and don’t have any clear idea of what to expect in the future. Several people that I know that are in the same predicament as me have simply closed their doors. I have way too much invested to do that. I am willing to stick this out-I do have faith that the FAA may be able to solve this. I just hope they can do it without too much time passing.There are plenty of the SLSA’s in the 87 knot and above class that have been producedunfortunately they simply would not work well in our environment and encompass what we are trying to achieve at this airpark. We are serving a large part of Light-sport that has been left behind by the new generation of fast Light-Sport, and hope to continue providing a very safe program for the lighter and slower end of Light-Sport.

Thank you very much for reviewing my request and look forward to hearing from you soon.

Dahl Cooper

4901 N. Axtell
Marana, Arizona 85653

Phone: Work: 520-682-7504

Cell: 520-349-0682
E-mail: azultralight8939@yahoo.comSPORT PILOT STUDENT TRAINING SYLLABUS

Student

Contact number Prior Experience

Start date

Date

Hour(s)

Lesson # 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20

Ground School Basic, FAR’s, X-ctry, Pract. Preflight Prep

Intro flight

Fundamentals

Shallow turns

Medium turns

Steep turns

S turns

Turns abt. pt.

Rec. Course

Stalls

Slow flight

Traffic pattern

Normal T.O.

Normal landing

Crosswind T.O.

Crosswind ldg.

Fwd. Slip

Precision lndg.

Short/soft fld.

Go around

Emerg. Proc.

X-country-dual

X-country-solo

Solo(s)