From: 1/25/2011

Jim Stephenson

231 SW Bonanza Gln

Lake City, FL 32025

269-209-1466

Dear Mr. Raymond Towles:

ASC objects to your denial of the exemption request to train in ELSA for initial training (FAA-2009-0340). A

copy of the your denial is attached for reference. ASC wishes to formally appeal this decision.

It appears that in the original request we allowed the real issue to get lost. In fact, the LODA, as published,

misses the point so badly that it snubs the community.

Without approval of this exemption many more pilots will die for lack of instruction. In addition, with the lack

of available instructors a much larger number of the 10,000 aircraft that did not come into Light-Sport Aircraft

will be flown by unsupported and untrained individuals.

The point is, we must have the very light trainers for ab initio (initial) training. The LODA prevents this initial

training. This means very light training must be preceded by much heavier/faster training. In most cases the

initial training in this way establishes habits that are detrimental ,or even hazardous, when converting to very

light aircraft (VLA).

The LODA also makes training less available. At one time there were over 4,000 active instructors in operating

trainers. They had a good safety record and provided close and appropriate instruction. With Sport Pilot we had

hoped to get a large number of converts to instructor. However, the FAA's implementation and dogged rigor

scared many away. We also did not covert many examiners and today a large number of them are being forced

out by inappropriate application beyond traditional GA approaches. For example, right now there is only one

powered parachute examiner East of Michigan.

From our earlier 4,000 instructors, we have now dropped to less than 1,000. Of those 1,000, less than 200 have

available aircraft that are SLSA. See the scale chart and answer the question, how does this support safety?

People are driving as much as 600 miles, one way, to get appropriate instruction. That is why many are giving up

and training themselves, sometimes in the remaining aircraft that are flyable but not inspected (ie. illegal).

Why are there so few SLSA in the VLA area? Manufacturers are chasing the higher cost aircraft. They can

recover their certification cost easier and cover overhead. VLA have been built, but in this VLA class for

"quicksilver-like" aircraft, only one individual ship has been made SLSA and it has not sold. Of the six powered

parachute manufacturers, three are basically defunct and two are on life support for finances. Perhaps this

exemption could be tailored to less than 87 knot aircraft to cover this critical area.

Why haven't there been demands for the SLSA in the VLA? The economy has dealt our community a double hit.

Instructors can not afford to risk the investment when the customers are so tight on discretionary funds. The

market place is being devastated right now. Yet, there is a need for instructors. We need to use the existing ships

to support the community.

See the original request for other details and requirements of an exemption request. 

"Aviation is not so much more dangerous as it is unforgiving of errors." Please help us find a way to use

instruction to minimize those errors. 

In support of the community,

Jim Stephenson

President/CEO ASC