To whom it may concern, 

In accordance with 91.319(h) and FAA Order 8900.1, Volume 3, Chapter 11, Section 1,1 am 

applying for a Letter of Deviation Authorily (LODA) for the purpose of condudtir^Cf|ig|^t t>^)i{jfi^ 

in my experimental light-sport aircraft per Part 61 Subpart J and K, and 61.56. 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 deviation 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 bahl Cooper, This letter is a request for a Letter of Deviation Authority (LODA). 

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 toking some training from an 

instructor named Don (Hawk) Wyatt. He was a very good pilot and instructor. In 1990,1 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 2006.1 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 Cessrvis 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 Marona 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 \earns 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 sa\fe most of their landings for the first hour of their tpalnlng. 

This type of training cannot be achieved with the faster fiberglass Light-Sport aircraft. Tve been 
doir^ 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 Rons 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 on idea\ 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 (N352PIC) for my 

student solo and solo work. My students complete their solo work in the Quicksilver Sport and then 

do their practical in the Rons 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, oil of the 100 hour 

Inspections and condition inspections are carried out by either an AAP 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 a LODA on any 

aircraft that have not already been in the Light-Sport training environment. I am not trying to 

start a new buslncss-my business has been in place for more than 20 years. 

The "low moss/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 C6S 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 Rons 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 troinlr^ environment. Most of those failures occurred 

with a student on board. I hove 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 Rons 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*^, 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 port 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 producedunf ortunately they simply would not work well In our environment and encompass what we are trylr^ 

to achieve at this airpark. We are serving a large pari 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 

Parana. Arizona 85653 

Phone: Work: 520-682-7504 

Cell: 520-349-0682 

E-mail: azultralight8939@yahoo.com 
Attached is a sample Sport Pilot Training Syllabus that I use. Most of my students are 

given a ground school package that I use from Gleim. It is a home study course which allows 

the student to study at their own pace. I give them areas to study in preparation for upcoming 

lessons and also to prepare them for the knowledge test. Typically, before each lesson we 

discuss any questions they might have in regards to what they are studying, and any questions 

they might have concerning the lesson for the day. We outline the lesson and complete 

preflight prep and then go flying. During their training course, we may interject ground school 

at different times to help them through difficult study outlines such as FAR's, cross county and 

also practical test prep. 

The attached syllabus is a 20 lesson format although most of my zero time students take 

longer than that. 

1) Typically, most of my students start the program with some basic ground school 

(basic aerodynamics, procedures, weather, decision making, etc.) Usually we spend about 3 

hours covering these topics and others. With several of my students, I don't do the ground 

school or even give them a ground school package (these students are typically private pilots 

or equivalent and are simply transitioning). 

2) We then start the student into flight training with a basic introductory type flight 

and start the flight instruction process with basic maneuvers. 

3) As student's confidence and skill start to advance, we introduce more maneuvers and 

review the maneuvers previously learned. 

4) We then introduce them to stalls (entered from straight & level flight) and slow flight. 

We will then introduce them to stalls with turns involved and leam about spin awareness and 

what happens in a turn-stall situation and how to recover properly. 

5) They now will start learning about how to properly return an aircraft to the ground 

and the process involved in the pattern and the approach process. 

6) As skills evolve, we tighten up the parameters and hone skills allowing them to land 

the aircraft where they want and the process of just how to do that. 

7) We then start into the Short/Soft field take-off and landings and how to use the 

forward slip to their advantage. 

8) Throughout the training process we interject the emergency scenario in many 

different ways helping them deal with stress and making the right decisions. 

9) Depending where they are with their skills and abilities, we may choose to do the 1'* 

solo. After 1" solo, they will spend several hours refining their skills and preparing for the 

upcoming practical. 

10) We then bring them back to the table for some cross country planning, weather 

resources and learning the sectionals-including airspace & decision making. 

11) At this point we will start the cross country flight training with diversions and 

usually emergency scenarios (a great time to do those especially out of their normal training 

environment). 

12) Once the dual instruction for the cross countries are complete, we like to send them 

off on their own cross country solo (of course, by this time they will have completed several 

hours of solo work in preparation for this. 

13) About this point they are ready to take their knowledge test and prepare for the 

practical test. Of course, some students are ready fairly quickly and others take a little while. 

We go over all the necessary paperwork and endorsements and call the examiner. 
SPORT PILOT STUDENT TRAINING SYLLABUS 

Student 

Contact number 

Prior Experience. 

Start date 

Date 

HoUr(s) 

Lesson # 

Ground School 

Basic, FAR's, 

X-ctry, Pract. 

Preflight Prep 

Intro flight 

Fundamentals 

Shallow turns 

Medium turns 

Steep turns 

Stums 

Turns abt. p t 

Rec. Course 

Stalls 

Slow flight 

Traffic pattern 

Normal T.O. 

Normal landing 

Crosswind T.O. 

Crosswind idg. 

Fwd. Slip 

Precision Indg. 

Short/soft fld. 

Go around 

Emerg. Proc 

X-country-dual 

X-country-solo 

Solo(s) 

1 2 

1 

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