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 31st, 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 occurred
with 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.com
SPORT 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)